World-Wide Volkswagen Corp. v. Woodson

Brief Fact Summary.

Family bought an Audi in New York, was driving to Arizona, and got into a car accident in Oklahoma. Oklahoma state attempts to assert jurisdiction over the dealer and distributor of the Robinson’s vehicle that only operated on the East Coast.

Synopsis of Rule of Law.

Foreseeability alone cannot establish a state court’s personal jurisdiction over a nonresident defendant that has no contacts or ties with the forum state. A retail distributor must purposefully avail themselves to the forum state by seeking to serve the forum in order to be liable for injuries that occur there.

Facts.

The Robinson family bought an Audi in New York, and while driving to Arizona to relocate there, got rear ended by another driver in Oklahoma. The car caught on fire injuring Mrs. Robinson and their children. The Robinsons sue the dealer and distributor, Seaway and World-wide Volkswagen in Oklahoma state court. Seaway and World-Wide Volkswagen contest the court’s jurisdiction  over them, but the trial court disagrees with them and allows the case to proceed. Seaway and World-Wide Volkswagen, Plaintiffs, appealed the decision to the Oklahoma Supreme Court against Defendant Woodson, the judge that allowed the case to proceed.

Issue.

Is foreseeability alone enough to establish a state court’s personal jurisdiction over a nonresident defendant that has no contacts or ties with the forum state?

Held.

No, foreseeability alone is not enough to establish a state court’s personal jurisdiction over a nonresident defendant that has no contacts or ties with the forum state. Ruling of the Oklahoma Supreme Court reversed, in favor of Plaintiffs Seaway and World-Wide Volkswagen.

Dissent.

Justice Justice Brennan dissenting

In determining personal jurisdiction over a nonresident defendant, a court may consider the interest of the forum state in presiding over the case and the burden of the defendant in defending in a distant forum. The minimum contacts test from International Shoe may be outdated.  Reasonableness and fairness are no longer as important for nonresident defendants in defending against a suit in a distant forum because of modern technology and modes of transportation. The Plaintiffs have contacts with Oklahoma in that they purposefully injected the Audi, which is by nature mobile, into the stream of interstate commerce. Personal jurisdiction is justified because the state has a strong interest in proceeding with the case and the nonresident defendant is not unduly burdened by defending in the forum state.

Justice Justice Marshall with Justice Blackmun dissenting

The nature of vehicles should tell dealers that their products will be used in different states and therefore they are open to lawsuits in that state.

Justice Justice Blackmun dissenting

Cars are intended for mobility and rarely stay in the vicinity in which they were sold. Therefore it is not unreasonable and does not go against International Shoe to uphold Oklahoma jurisdiction over Plaintiffs.

Concurrence.

Justice Justice Blackmun dissenting

Cars are intended for mobility and rarely stay in the vicinity in which they were sold. Therefore it is not unreasonable and does not go against International Shoe to uphold Oklahoma jurisdiction over Plaintiffs.

Discussion.

1. The purpose of the minimum contacts test is to protect nonresident defendants from far off litigation and to curb state judges from exercising personal jurisdiction that is too broad. But, the test is also used to protect state sovereignty.
2. The Framers of the Constitution intended for states to be interconnected but sovereign and independent. However, each state’s sovereignty has a limit, implicit in the Fourteenth Amendment and the rest of the Constitution.
3. Asserting jurisdiction over a defendant must take federalism into account.
4. Although the state has an interest in exercising jurisdiction over nonresident defendants, Seaway and World-Wide Volkswagen are not subject to Oklahoma laws because they did not sell cars or engage in advertising that was calculated to reach Oklahoma consumers, nor did they benefit from Oklahoma laws. The Robinsons’ car accident is an isolated event.
5. As for foreseeability, foreseeability does not automatically equal personal jurisdiction. It is unreasonable to think that “amenability to suit travels with the chattel” and that a dealer and distributor can be sued in whatever forum their product is brought into by a consumer.
6. Foreseeability in this context means that defendant’s conduct and connection with the forum state are such that he should reasonably anticipate being hailed into court in the forum state, not just that he can foresee his product being used in the forum state.
7. As for substantial revenue derived from the state, “financial benefits accruing to the defendant from a collateral relation to the forum state will not support jurisdiction if the financial benefits do not stem from a constitutionally cognizable contact with that State”, and here the connection is too attenuated. There must be foreseeability along with purposeful availment.
8. Personal jurisdiction over Seaway and World-wide Volkswagen is improper.