World-Wide Volkswagen Corp. v. Woodson [Robinson]
444 U.S. 286 (1980)
Author: Jim

Facts:  Defendant World-Wide Volkswagen is a wholesale distributor which is based in New York.  It supplies vehicles and parts to dealerships in New York, New Jersey, and Connecticut.  Defendant Seaway is a car dealership that is located in New York and receives vehicles form World-Wide. The plaintiffs bought an Audi from Seaway and while they were driving this vehicle in Oklahoma, they were struck by a drunk driver and the care busted into flames and the plaintiffs were severely burned.  The plaintiffs brought suit against the defendants in an Oklahoma court.

Procedure:  The trial court ruled that the ct. had jurisdiction over the defendants.  The Supreme Court of Oklahoma affirmed.

Issue: Can the Oklahoma court practice in personam jurisdiction over the defendants under the given circumstances?

Holding: No

Rationale:  Even though the courts have extended the jurisdiction criteria since the days of Pennoyer, but limitations still exist and state lines are still important under the Due Process Clause of the Constitution.  The defendants in the current case did not have any business in Oklahoma, had no agents in Oklahoma, showed no advertisement in Oklahoma.  So the plaintiffs seek to establish minimum contact through this one isolated incident that occurred in Oklahoma.  Furthermore, the ruling to the Oklahoma Sp. Ct. that an automobile is extremely mobile and therefore it was foreseeable for the defendants that one of their vehicles will travel into Oklahoma is also without merit.  Foreseeability alone has never been sufficient benchmark for personal jurisdiction under Due Process Clause.  Foreseeability comes into play when the defendants contacts with the forum state are such that the defendant can foresee that he will be held under the forum state’s jurisdiction is conflict arises.  Therefore, just because the defendants put a product in the stream of commerce does not mean that they formed the sufficient contact with Oklahoma to be held under its jurisdiction.