World-Wide Volkswagon v Woodson
444 U.S. 286 [1980]
Author:- Sam Biers

Relevant Facts: Resp. purchases a new Audi from Pet. Seaway Volkswagon in NY. The following year they left NY for a new home in AZ.  As they passed through OK another car struck their Audi in the rear, causing a fire which severely burned Resp’s wife and two children.

Legal Issue(s): Whether corporate Dfs, automobile wholesaler and retailer, who carried on no activity whatsoever in Oklahoma and availed themselves of no privileges or benefits of Oklahoma law, mere fortuitous circumstance that a single automobile sold in New York to New York residents happened to suffer an accident while passing through Oklahoma constituted "minimum contacts" with Oklahoma so as to permit Oklahoma courts to exercise jurisdiction consistently with due process?

Court’s Holding: No

Procedure: Tr ct ruling for Resp. Ok S. Ct denied appeal by Pet; Pets appealed; Reversed

Law or Rule(s): Due process clause of Fourteenth Amendment limits power of state court to render valid personal judgment against nonresident defendant. State court may exercise personal jurisdiction over nonresident defendant only so long as there exist "minimum contacts" between defendant and forum state.

Court Rationale: The record has a total absence of those affiliating circumstances that are a necessary predicate to any exercise of state-court jurisdiction.  Petitioners carry on no activity in OK whatsoever.  They close no sales and perform no service there.  They avail themselves of none of the privileges and benefits of Ok law.  They solicit no business there either through salespersons or advertising.  Foreseeability alone has never been a sufficient benchmark for personal jurisdiction under the D. P.  But foreseeability applies to a dfs conduct and connection w/ the forum State such that he should reasonably anticipate being haled into ct. there.  If the sale of a product is not simply an isolated occurrence, it is not unreasonable to subject it to suit in one of those States if its allegedly defective merchandise has there been the source of injury. It is foreseeable that autos sold by WWV and Seaway may take them to OK, but the mere unilateral activity of those who claim some relationship w/ a nonresident df cannot satisfy the requirement of contact with the forum state.  Financial benefits accruing from collateral relations will not support jurisdiction if they do not stem fro a Constitutionally cognizable contact w/ the State. Pet have no contact, ties, or relations w/ the State of OK.

Respondent’s Argument: The mobility of the auto with the nature of the Pet’s business creates a situation where it is foreseeable that the product would enter the stream of commerce; OK.

Petitioner’s Argument: The Petitioner does not do business in OK, has no sales, salesmen, agents, or retail offices.  Pet does not have any contact with OK at all.

DISSENT: The interest of the forum State and its connection to the litigation is strong. The accident occurred in OK.  The Pl were hospitalized in OK when they brought suit. Essential witnesses and evidence were in OK.  The State has a legitimate interest in enforcing its laws designed to keep its highway system safe, and the trial can proceed at least as efficiently in OK as anywhere else. The petitioners are not unconnected with the forum state.  Each sold the auto which in fact was driven in OK where it was involved in an accident.  It is not that the dealer foresees that they will move, but the dealer actually intends that the purchasers will use the automobiles to travel to distant States where the dealer does not directly “do business.”

Sub-Notes on Rule:

A state court may exercise personal jurisdiction over a nonresident defendant only so long as there exist "minimum contacts" between the defendant and the forum State. The defendant's contacts with the forum State must be such that maintenance of the suit does not offend traditional notions of fair play and substantial justice, and the relationship between the defendant and the forum must be such that it is "reasonable . . . to require the corporation to defend the particular suit which is brought there," The Due Process Clause "does not contemplate that a state may make binding a judgment in personam against an individual or corporate defendant with which the state has no contacts, ties, or relations."