World-Wide Volkwagen Co. (& Audi) v. Woodson, U.S. Supreme Court (1980)
Author: Bram

Cause of action: The following is a cause of action for repeal of a rejection for a writ of prohibition against the D.C. judge for Creek County, OK by respondents who face the possibility of being brought into a product-liability suit by petitioner (PL).

Procedural History: Products liability action in District Court for Creek County, Oklahoma.  Respondents entered special appearance, claiming OK's restrictions on them would be against the limitations set forth in the constitution's 14th amendment, which was rejected.  Petitioners then sought writ of prohibition in OK Supreme Court, trying to stop the D.C. judge from exercising personal jurisdiction over them, which was also denied. Court found the long arm statute allowed the D.C. judge to exercise such power.  Appealed, given certiorari and reversed in Supreme Court.

Facts: Family bought Audi from petitioner in Massena, NY.  The next year they travel to Arizona to relocate and get into an accident in OK, resulting in the car catching on fire and burning Mrs. Robinson and her two kids.

Issue(s): Whether, under the due process clause of the 14th amendment, an OK court may exercise in personal jurisdiction over a nonresident automobile retailer and its wholesale distributor in a products-liability action, when the DF's only connection w/OK is the fact that an automobile sold in NY to NY residents became involved in an accident in OK?

Court's Rationale/Reasoning: The purpose of the rule below is to protect potential defendants fro prosecution in a distant or inconvenient forum, and so states do not overreach their legal boundaries in taking cases into their courts which have no business of being there.  The standard is one of reasonableness/fairness., and must not offend "the traditional notions of fair play and substantial justice."

The suit must be reasonable so as to "require the corporation to defend the particular suit which is brought there."  There are several factors which the Court looked to as to why the D.C. would want to take this case: (1)  PL's interest in obtaining convenient and equitable relief; (2) efficiency to resolve the controversy within the interstate judicial system; and (3) the shared interest of the several states in furthering fundamental substantive social policies.

In that respect, petitioners do not fit into any of the requirements set forth in past case law which would rope them into personal jurisdiction from an OK court.  They don't conduct any business there: no sales, no services, no use of OK law in any case, and no selling of cars in OK.  All the respondents have is the accident's location.

The court tosses aside the foreseeability argument, as it was not intended to be read that way in the due process clause.  No party should be brought to court in a particular on the basis a product could be foreseeably be brought into that particular jurisdiction.  It is the conduct of the defendant in conjunction with what happened to the complainant and the location therein which should be considered.

Rule: A state court may exercise personal jurisdiction over a nonresident defendant as long as there exist "minimum contacts" between the DF and the forum state.

Holding: No.  Respondents never proved the petitioners were, in any way, interrelated within the workings of the state which they sought personal jurisdiction in, save for the car accident which caused the damages for which they seek a remedy.

Dissent: (Brennan) The respondents indeed have contacts as they have illustrated: the accident, the jurisdiction where they were injured and hospitalized, and where they may to their best abilities bring this suit to court.  The majority in this decision read the law from Int'l. Shoe too narrowly, dismissing the possibility the reason the Supreme Court of OK ruled in favor of the plaintiff was that their state would be the best state and the most convenient financially and physically to bring suit.  Brennan feels there wouldn't be all that much of a [heavy and disproportionate] burden for the DF to argue this suit in OK, or anywhere else for that matter.

(Marshall, Blackmun) The basis for bringing the DF/petitioner to suit in this case should not be just the fact there was an accident in OK.  Instead, the Court's majority should have looked to the actual intent of the DF here, which would show their actual intent was to have their products driven and sold across the country.  It is not contended the foreseeability of knowing when and where a particular car would be on the road, but the fact that a car would be on the road is the dissenters' argument.