You are on page 1of 2

Personal Jurisdiction

World-Wide Volkswagen Corp. v. Woodson


444 U.S. 286 (1980)
Procedure:
The Robinsons brought a products-liability action in the District Court of
Oklahoma, against Audi, Volkswagen (VW), and petitioners VW World-Wide
(regional distributor) and Seaway (retail dealer). VW World-Wide and Seaway
entered special appearances, claiming that Oklahomas exercise of jurisdiction
over them would offend the limitations on the states jurisdiction imposed by the
14th amendment DPC. The petitioners sought a writ of prohibition in the Supreme
Court of Oklahoma to prevent the district court from exercising in personam
jurisdiction over them. The writ was denied and the Oklahoma Supreme Court
rendered judgment in favor of the Robinsons. Petitioners were granted a writ of
certiorari.
Facts:
Respondents (Robinsons) purchased a new Audi vehicle from petitioner Seaway in
New York. A year after the vehicle was purchased, the Robinson family who
resided in N.Y., left that state for a new home in Arizona. While passing through
the state of Oklahoma, another car rear-ended their Audi; injuries resulted to
multiple passengers of the Audi. Petitioners VW World-Wide and Seaway are fully
independent corporations whose relations with each other and with VW and Audi
are contractual only. Petitioners do not conduct any business whatsoever in the
state of Oklahoma. In fact, there was no showing that any vehicle sold by VW
World-Wide or Seaway has ever entered Oklahoma (excluding the vehicle involved
in this case). The Supreme Court of Oklahoma denied petitioners requested writ
of prohibition reasoning that because the product that was sold by the petitioners
is designed to be mobile, petitioners could have foreseen the possibility that it
would be used in Oklahoma. Also asserting that it was reasonable to infer that
based of the retail value of the vehicle, petitioners derive substantial income from
vehicles, which from time to time are used in Oklahoma.
Issue:
Under the 14th amendment DPC, can a forum state exercise in personam
jurisdiction over a nonresident defendant by virtue of an isolated occurrence?
Law:
Predictability Rationale:
o Jurisdiction is appropriate only where defendants conduct and connection
with the forum are such that he should reasonably anticipate being hailed
into court there.
Reasoning:
The DPC doesnt contemplate that a state may make binding a judgment in
personam against an individual or corporate defendant with which the state has
no contacts. The record provided that petitioners did not partake in any business
in Oklahoma, purposefully avail itself of the privileges of conducting business in
the state. The court explained that the foreseeability that is critical to due process
analysis is not merely the likelihood that a product will find its way into the forum
state. Rather, its that the defendants conduct and connection with the forum
state are such that he should reasonably anticipate being haled into court there.
The court also stated that financial benefits accruing to defendant from a
collateral relation to the forum state would not support jurisdiction if they do not
stem from a constitutionally cognizable contact with the state. Whatever marginal
revenues petitioners may receive by virtue of the fact that their products are

Personal Jurisdiction
capable of use in Oklahoma is far too attenuated a contact to justify the states
exercise of in personam jurisdiction over them.
The court examined the Reasonableness Factors: (Even if the reasonableness
factors support
jurisdiction, there can be no jurisdiction without minimum
contacts)
o Burden on Defendant
o States interest in adjudicating the dispute
o Plaintiffs interest in obtaining convenient and effective relief
o Interstate judicial systems interest in obtaining most efficient resolution of
the controversy
o The shared interest of the several states in furthering fundamental
substantive social policies
Holding:
Because the court could not find that petitioners had any contacts, ties, or
relations, with the state of Oklahoma, the judgment of the Supreme Court of
Oklahoma is REVERSED.
Dissent:
Brennan reasoned that the courts opinions focus tightly on the existence of
contacts between the forum and the defendant. He contends that they did not
place enough weight on the strength of the forum states interest in the case
without exploring the possibility of any actual inconvenience to the defendant.
Brennan argued that the state has a legitimate interest in enforcing its laws
designed to keep its highway system safe, and the trial can proceed just as
efficiently in Oklahoma as anywhere else. The very purpose of an automobile is
for it to be mobile. Brennan asserted that someone in the business of selling cars
cannot plead ignorance of their mobility and that they had to anticipate the
possibility of the vehicle entering a state outside their limited territory of
business. Brennan claims that the courts opinion suggests that the defendant
can only be subject to a states jurisdiction if has contact with the state such that
he should reasonably anticipate going there. Brennan further argued that if the
plaintiff can prove actual injury and the defendant couldnt show some real injury
to a constitutionally protected interest, there is no excuse why he shouldnt
appear.

You might also like