The International Shoe Co. v. State of Washington case in 1945 was a landmark decision by the U.S Supreme Court that established the principle of minimum contacts for determining whether it is fair and just to subject a defendant to lawsuit within a state. The court ruled that if an out-of-state company has sufficient contact with the state where it does business, then it can be sued in that state's courts under its laws. In this case, International Shoe Company, based in St Louis, Missouri had salesmen working on commission basis in Washington but argued they didn't have enough presence there to be subjected to their jurisdiction or tax laws. However, the court found otherwise stating that because they received benefits and protection from those states' laws (like police force), they should also bear obligations such as paying unemployment taxes for employees working there.

In the dissenting opinion for International Shoe Co. v. State of Washington, Justice Frank Murphy argued that the majority's decision to allow states to exercise jurisdiction over out-of-state corporations based on their "minimum contacts" within a state was too vague and could lead to arbitrary results. He contended that this standard did not provide sufficient protection for interstate commerce from potentially burdensome litigation in remote jurisdictions. Instead, he proposed a more stringent test: whether the corporation's activities in the state were so substantial and of such nature as to render it essentially at home there. This would ensure fairness by limiting jurisdiction only to those places where companies have significant operations or affiliations, thereby preventing them from being hauled into court anywhere they happen do business.