Also known as: International Shoe · Int'l Shoe · minimum contacts · Shoe test
Written by attorneys · grounded in primary & secondary sources — see below
A due process standard for exercising personal jurisdiction over nonresident defendants. The standard requires minimum contacts with the forum state such that the suit does not offend traditional notions of fair play and substantial justice.
Ivan Ivanov, a resident of State A, negotiated a supply contract with Ivy Investments through repeated emails and calls directed to State A. Ivy Investments never sent personnel or property into State A. When a dispute arose, Ivan sued Ivy Investments in State A. The court lacked jurisdiction because Ivy Investments did not purposefully avail itself of State A.
Ira Irving, a State B resident, contracted with Innovate Pharmaceuticals for repeated shipments over two years. All performance occurred outside State B and communications were remote. Ira sued in State B after a quality dispute. The court could exercise jurisdiction because the defendant's contacts satisfied minimum contacts and fairness.
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Israel Irving owned land in State C unrelated to a tort claim arising in State D. The plaintiff attached the land to obtain quasi in rem jurisdiction. The court lacked jurisdiction because the property alone did not create sufficient contacts with State C.
Irene Ingalls purchased a product in State E containing a part made by Ideal Solutions abroad. Ideal Solutions knew the part would reach State E but took no other action there. Irene sued in State E after an injury. The court lacked jurisdiction because mere awareness of the stream of commerce did not establish minimum contacts.
Imran Iyer, a State F resident, sued a company after a contract dispute. The company maintained continuous and substantial operations inside State F over many years. Imran sued in State F. The court could exercise jurisdiction because the company's ongoing activities satisfied the contacts test.
Iris Irons, a State G resident, sued Ivy Investments after a product injury in State G. Ivy Investments was incorporated and headquartered elsewhere but sold thousands of units in State G over many years. The court lacked general jurisdiction because the company was not at home in State G.
The defendant must have purposefully availed itself of the forum. The claim must arise out of or relate to those contacts. The exercise of jurisdiction must be reasonable under traditional notions of fair play and substantial justice.
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No. The framework replaced strict territorial presence with a contacts-based inquiry focused on minimum contacts and fairness.
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No. The framework requires minimum contacts even for quasi in rem actions, so unrelated property is insufficient.
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Unilateral activity by the plaintiff or a third party cannot satisfy the purposeful availment requirement.
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Even with minimum contacts, jurisdiction must still comport with traditional notions of fair play and substantial justice.
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International Shoe Co. v. Washington <!-- acedexams opinion md v1 -- Case information - Court: Supreme Court of the United States - Citation: 326 U.S. 310, 66 S.Ct. 154, 90 L.Ed. 95, 161…