Internat'l Shoe Co. v. Washington

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Internat'l Shoe Co. v. Washington
Court U.S. Supreme Court
Citation 326 U.S. 310 (1945)
Date decided

Facts: Internat'l shoe Co. employed 11-13 salespeople in the state of WA during the years of 1937-40. During that time, the defendant's employees in WA didn't have authority to make contracts and they were compensated by the defendant. The state tried to collect taxes to fund the State's unemployment fund.

Procedural History: Commissioner of the State unemployment fund served the notice of assessment on a salesman in the state as well as mailed the notice to the corporate HQ in Missouri. Motion to dismiss was denied, Superior and Supreme Cts of the State affirmed jurisdiction of the state.

Issues:

  1. Whether the defendant is under the jurisdiction of the State Ct. in Washington to collect unpaid taxes by virtue of the activities it conducted in the State.
  2. Whether the State can take those unpaid funds.

Both issues are related to the 14th amendment. These issues are based on the presence of the defendant in the State.

Holding: The State does have jurisdiction over the defendant. The State is allowed to collect funds.

Judgment: Affirmed

Reasons: By virtue of the defendant's many transactions within the state, they are required to pay the taxes and they fall within the State's jurisdiction. The defendant received the benefit of protection under the law while it was in the state. The summons sent to the local salesman and the company office, both of which should qualify. Presence in the State is can be established by the activities committed.

Note: Mr. Justice Black concurred with the opinion. He disagreed with the terms "fair play" and "sense of justice" etc. because they turned the judgment into arbitrary decisions.