World-Wide Volkswagen Corp. v. Woodson (U.S. Supreme Court, 1980)
Facts
Procedure
Respondents bought an Audi from petitioner Seaway Volkswagen in
Massena, NY in 1976. In 1977 the family drove through Oklahoma, where
their Audi was struck by another car, causing a fire which severely burned the
mother and two children.
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Robinsons brought product-liability action in Creek County, OK District
Court against automobile manufacturer, importer, regional distributor,
and retail dealer, Seaway
Seaway and World-Wide entered special appearances (appearance
in court solely to challenge personal jurisdiction), claiming State did
not have personal jurisdiction in Oklahoma per Due Process Clause
of 14th Amendment
District Court denied petitioner’s constitutional claim
Petitioner’s sought writ of prohibition in Supreme Court of Oklahoma
Supreme Court of Oklahoma Denied writ
Petitioners granted certiorari in U.S. Supreme Court
U.S. Supreme Court reverses decision of Oklahoma Supreme Court
Issue
Does the Oklahoma court system have personal jurisdiction over Volkswagen
et. al, since it is incorporated in New York?
Holding
A state court may not exercise personal jurisdiction over a non-resident
defendant if there were not “minimal contacts” between the defendant and
the forum State. The mere fact that a product sold has the potential to pass
through the state is not sufficient to establish minimal contacts
Reasoning
Seaway and World-Wide only operate in the tri-state area, and mere
“foreseeability” that product could be used in Oklahoma or marginal revenues
gained from ability to be used in that state are not sufficient to justify sufficient
“minimal contacts” with Oklahoma under the Due Process Clause of the 14th
amendment
Disposition
U.S. Supreme Court reverses Oklahoma Supreme Court’s holding