WORLD-WIDE VOLKSWAGEN v. WOODSON (Trial Ct. Judge)

Procedural Basis: Writ of Certiorari to the Supreme Court of Oklahoma, for its denial of the ?’s writ of prohibition to restrain the trial court judge from exercising personal jurisdiction over them.

Facts: While the Robinson family was traveling to Arizona when their Audi caught on fire in Oklahoma.  The wife and two children required hospitalization in Oklahoma.  Since the driver of the other car that hit them was not wealthy, the Robinsons brought a product liability suit against the car’s manufacturer, Audi, claiming that the gas tank and fuel system were defective.  They filed the suit in Oklahoma state court and named as additional defendants the cars importer, Volkswagen, its regional distributor World Wide, and Seaway, the retail dealer where the car was purchased.  Audi didn’t challenge jurisdiction b/c they have plenty of sales in Oklahoma.  World Wide and Seaway challenged the Oklahoma court’s jurisdiction claiming that they did not have the minimum necessary contacts w/ Oklahoma.  Seaway (?) claimed to do business in New York only and World Wide claimed to do business only within the tri state area including New York, New Jersey and Connecticut.  Neither conducted any business in Oklahoma, employed anyone in Oklahoma, kept office space in Oklahoma, or advertised in Oklahoma.

Procedural History:  Both the trial court and the Supreme Court of Oklahoma found that World Wide (?) and Seaway (?) should be subjected to jurisdiction there b/c they should have foreseen the possibility of litigation there given the mobile nature of the product they sold.  World Wide (?) and Seaway (?) appealed to the U.S. Supreme Court.

Issue: When a particular state would be the most convenient forum for a trial (witnesses are there, Plaintiff’s are hospitalized there, claim arose there, etc.) and the ? would not find it at all inconvenient to defend itself there, can that state exercise jurisdiction even if the ? has not deliberately sought contacts with that state?

Rule: In order to be subjected to a state’s jurisdiction, a ? must have chosen to have some contact with that state, considerations of fairness, convenience, and the interests of the state in overseeing the litigation are otherwise irrelevant.

Application: A state can’t exercise jurisdiction over a ? who has not deliberately sought some contact with the state.  Minimum contacts must be based on some act committed by the defendant.  It is fundamentally unfair to hold a ? responsible for the actions of others.  It is reasonable to believe that neither Seaway nor World Wide expected to be haled into court in Oklahoma.

Conclusion:  Judgment reversed.

Dissent: (Brennan) Considering fairness and convenience, it is reasonable to subject World Wide and Seaway to Oklahoma’s jurisdiction for this case.

Notes from World Wide Volkswagen v. Woodson

The forum state does not exceed its powers under the Due Process Clause if it asserts personal jurisdiction over a corporation that delivers its products into the stream of commerce w/ the expectation that they will be purchased by consumers in the forum state.

Robinsons wanted to add Seaway as a ? b/c they wanted to be in state court and this would eliminate diversity.

Foreseeability alone is insufficient as a basis for jurisdiction.

If you can sue car dealership anywhere car goes, people won’t want to sell cars b/c people could take cars overseas if they wanted.

Went after constitution b/c state court already said that statute applied.

Hypo:

Q: Would result be different if plaintiff’s were in Pennsylvania hospital?

A: The only thing being challenged is the distance so it would be fair and reasonable b/c distance is a lot less making it more foreseeable to be “haled into court.”