Also known as: minimum contact test · minimum contacts · International Shoe test
Written by attorneys · grounded in primary & secondary sources — see below
A constitutional standard for determining whether a court may exercise personal jurisdiction over a nonresident defendant. The defendant must have contacts with the forum state of such quality and nature that maintaining the suit does not offend traditional notions of fair play and substantial justice. Purposeful availment by the defendant is required, and unilateral activity by the plaintiff cannot create the necessary connection.
Matthew Martinez, a resident of State A, mailed a contract offer to Michael Miller in State B. Miller signed and returned the document without traveling to State A or initiating any dealings there. When Martinez later sued Miller in State A over a payment dispute, the court dismissed for lack of personal jurisdiction because Miller had not purposefully directed any activity toward the forum.
Mercury Industries sent multiple sales representatives into State A to display products and solicit orders from local buyers. The orders became binding only after acceptance at the company's headquarters in State B. When a State A customer sued over a defective product, the court upheld personal jurisdiction because the company's deliberate solicitation established sufficient contacts with the forum.
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Maria Morales owned shares in a State A corporation but lived and worked exclusively in State B. A State A plaintiff brought an unrelated breach-of-fiduciary-duty claim and sought to attach the shares to establish jurisdiction. The court dismissed the action because the mere presence of the shares in the forum did not supply minimum contacts tied to the dispute.
Meredith Maxwell lived with her child in State A for several years before moving to State B. The other parent remained in State A and filed a support action there. The court found personal jurisdiction proper because Maxwell's prior residence with the child in the forum created the required connection to the support claim.
Matrix Technologies manufactured component parts in a foreign country and sold them to a company that incorporated the parts into products distributed nationwide. One product reached State A and caused injury there. The court held that mere awareness that the parts might enter the forum through the stream of commerce did not constitute purposeful availment sufficient for jurisdiction.
Meridian Motors maintained its headquarters and principal manufacturing facilities in State B. Although some of its tires were sold in State A through independent dealers, the company conducted no other operations there. When a State A resident sued over an accident that occurred outside the forum, the court ruled that the sporadic sales did not render the company at home in State A for general jurisdiction purposes.
Yes. The standard governs all exercises of state-court jurisdiction, including actions that seek to adjudicate interests in property located in the forum. Mere ownership of unrelated property in the state is insufficient to support jurisdiction over a nonresident defendant.
The defendant must purposefully avail itself of the privilege of conducting activities in the forum state so that it invokes the benefits and protections of the forum's laws. Unilateral activity by the plaintiff or a third party cannot satisfy this requirement.
Even when minimum contacts exist, the exercise of jurisdiction must not offend traditional notions of fair play and substantial justice. Courts weigh the burden on the defendant, the forum state's interest, the plaintiff's interest in convenient relief, and the interstate system's interest in efficient resolution.
Yes. In child support proceedings, a nonresident parent's prior residence with the child in the forum state supplies a statutory and constitutional basis for personal jurisdiction under the minimum contacts framework.
…to subject a defendant to a judgment in personam , if he be not present within the territory of the forum, he have certain minimum contacts with it such that the maintenance of the suit does not offend “traditional notions of fair play and substantial justice.” Milliken v. Meyer , 311 U. S. 457, 463. See Holmes, J., in…