World-Wide Volkswagen Corp. v. Woodson

Facts: The plaintiffs, Harry and Kay Robinson, purchased a new Audi in New York state. The following year the Robinsons were moving to Arizona and were involved in an automobile accident in Oklahoma. In the accident, the Robinsons were rear-ended, and their Audi caught fire, burning Kay and the Robinson's two kids.

Procedural History: Plaintiffs brought a products-liability action in the District ct for Creek County, Okla. Defendants were Audi (the manufacturer), Volkswagen of America (the importer), petitioner World-Wide Volkswagen Corp. (regional distributor), and petitioner Seaway Volkswagen, Inc. (car sales lot). Seaway and World-Wide entered special appearances, claiming that the state had no jurisdiction under the 14th amendment's due process clause. District Court rejected constitutional claim and denied motion for reconsideration. Petitioners sought a writ of prohibition in the Oklahoma Supreme Court to restrain the District judge, respondent Charles Woodson, from exercising in personam jurisdiction over them.

Issue: Whether an Oklahoma Court can exercise in personam jurisdiction over nonresident automobile retailer and its distributor when their only contact with the state is that one car they sold that was involved in a car accident in Oklahoma.

Holding: The Oklahoma ct cannot exercise in personam jurisdiction over the New York state companies.

Judgment: Reversed; for the petitioners (defendants).

Reasons: There was not the requisite minimum contact between the defendants and the state. The fact that is was possible and foreseeable that the products sold would travel to another state doesn't satisfy the minimum contact with the seller and whatever state. If "foreseeability" constituted sufficient contact for jurisdiction, then many other cases even more extreme could be brought before the court. The defendants gain neither benefit nor privileges of Oklahoma law. They do not attempt to sell their product there, and whatever financial advantages of their products being able to travel to Oklahoma is a very slim one.

Dissenting Opinions:

• Justice Marshall argued that the sellers of the automobile shouldn't have been surprised when their car ended up being in Oklahoma. They are part of a nation-wide organization of dealerships and service centers. A buyer in NY can get his car service in OK. Defendants are part of that organization because it brings economic benefit. The petitioners knowingly cause an effect in other states and receive economic advantage both from that ability to cause such effects and from the existence of dealers and distributors in the other states.
• Justice Blackmun: look at the wide range of state license plates on an average highway or in an average city. The cars travel all around the nation.