Shoe Co. v.
Yeazell, p. 95-100
Facts: International Shoe is a
Shoe made a special appearance in
Issue: Under what conditions is a corporation subject to personal jurisdiction in a particular state?
Rule: A corporation that is protected by the laws of a state shall be subject to personal jurisdiction in that state.
Analysis: The court interprets the due process clause and the Fourteenth Amendment to mean that if a company has “sufficient contacts” in a state, they may be subject to being sued in that state.
Chief Justice Stone relies upon the concept of “fair play”, whereas Justice Black takes a harder line and says that under more or less no circumstances should a state’s law be found not to apply simply because it doesn’t meet the court’s standard of “fair play”.
Court upheld the lower court’s ruling for the state of
Notes and Problems
a. The court
could only have reached a different result if it found that the activities of
the company in
b. I think requiring the court to notify the parties if it is going to make a mind-blowing doctrinal change would make things too complicated and delay the proceedings too much. Hopefully, if the attorneys from both sides have been reading law reviews and are familiar with the records of the judges involved, they will be able to anticipate the changes when they write their briefs.
2. This does seem like an awfully vague standard, but the Court seems to suggest that the standard is necessarily vague. If the salespeople are freelancers, the companies that pay them will all be protected by the laws of that state, so presumably they would all be under the personal jurisdiction of that state. If the salesmen travel to other states, the protection of those other states’ laws will apply to them. It would seem that personal jurisdiction would apply in those states as well.
3. The statement suggests that if your corporate operations in a certain state are “continuous” and “substantial”, you could be subject to personal jurisdiction on a whole host of issues.
a. If a corporation does a good amount of business in a state, it seems to be more or less “black letter” that the corporation is subject to general jurisdiction in that state. These would not be hard cases.
b. If the corporation does limited business in a state, the court must decide if the state has specific jurisdiction on a particular issue based on how connected that limited business is to the specific issue in question.
4. Oh boy,
hypotheticals! We’re told that Shoe
still has its headquarters in
a. It would seem
that the company doesn’t have sufficient contacts to be subject to personal
b. I don’t think
the company would be subject to personal jurisdiction in this case either for
similar reasons. The person is not a current
employee, and the alleged wrongdoing didn’t take place in
c. It would not
make any difference which plaintiff sued in
d. I think this
would be no different than case 4c. The
e. The issue here
5. Are there situations where we can clearly see that a defendant may be sued for all claims in a certain state?
a. If you’re incorporated in a state, you can be sued there for anything. If you’re a person domiciled in a state, you can also be sued there for anything. The induced consent comes from the idea that whatever the state creates, it can mess with or destroy. If you agree to incorporate in my state, you have to be subject to the rules I set up.
b. If you’re domiciled in a state, you can be served in that state even if you’re out of state at the time. This seems like a change from Pennoyer.