Worldwide Volkswagen v. Woodson

Brief Fact Summary.

The Robinsons purchased a car in New York. The next year, they were involved in and sustained injuries from an auto accident that occurred while they were driving in Oklahoma. Claiming that defective design and construction of the car caused their injuries, the Robinsons brought a products liability action against against Petitioners (and others) in state court in Oklahoma. The state court rejected a lack of jurisdiction claim raised by Petitioners, and denied a motion for reconsideration. Petitioners sought a writ of prohibition from the Oklahoma Supreme Court to restrain the lower court form exercising jurisdiction. The Oklahoma Supreme court denied the writ. The Supreme Court granted certiorari.

Synopsis of Rule of Law.

Due process does not contemplate the imposition of jurisdiction over a defendant who has no contacts, ties or relations with a state;  the due process clause may divest a state of jurisdiction even if there is minimal inconvenience to the defendant, the forum has a strong interest in deciding the matter, and the state’s forum is the most convenient location for litigation.

Facts.

While driving to their new home in Arizona, the Robinsons, who had purchased a car the year before from Petitioner Seaway, in New York, were involved in and sustained injuries from an auto accident. The accident occurred in Oklahoma. The Robinsons brought a product liability against against Petitioners (and others) in state court in Oklahoma after the accident, claiming that defective design and construction of the car caused their injuries. Petitioners claimed that the Oklahoma court lacked jurisdiction over them; Seaway was incorporated and had its principal place of business in New York, and World-Wide Volkswagen was incorporated and had its business office in New York. The Oklahoma state court rejected the Petitioners’ lack of jurisdiction claim, and denied their motion for reconsideration. Petitioners sought a writ of prohibition from the Oklahoma Supreme Court to restrain the lower court form exercising jurisdiction. The Oklahoma Supreme court denied the writ. The Supreme Court granted certiorari.

Issue.

Could the Oklahoma state court properly exercise jurisdiction over Petitioners, a nonresident auto dealer and its wholesale distributor, in a product liability action if their only connection to Oklahoma was the fact that the accident that led to the product liability action occurred in Oklahoma?

Held.

No. Petitioners did not have “contacts, ties or relations” with Oklahoma to serve as a basis for the exercise of the Oklahoma court’s jurisdiction.

Dissent.

Justice Brennan

Justice Brennan’s dissent argued that the Court’s decision was too narrow, based on International Shoe and subsequent personal jurisdiction cases. He argued that the Court’s decision gave too little consideration to the strength of Oklahoma’s interest in the case, and failed to consider whether there was actual inconvenience to the Petitioners.

Discussion.

The Court found that there were no factors or circumstances upon which jurisdiction court be predicated, noting:

• Petitioners carried on no activities in Oklahoma
• Petitioners closed no sales and performed no services in Oklahoma
• Petitioners availed themselves of none of the privileges or benefits of Oklahoma law
• Petitioners solicited no business in Oklahoma
• Petitioners did not regularly sell cars in Oklahoma