After suffering injuries in a car accident in Oklahoma, Plaintiffs filed a products liability suit in Oklahoma against Defendants. Defendants argued that the lawsuit lacked in personam jurisdiction.
To be subject to in personam jurisdiction under the Due Process Clause, a nonresident defendant must have minimum contacts with a state such that they could reasonably anticipate being called into court in that state.
Harry and Kay Robinson (Plaintiffs) bought a car in New York when they were residents of the state. While driving through Oklahoma to their new home in Arizona, the Plaintiffs’ were in an accident in which their car caught on fire. Plaintiffs brought a products liability suit under Oklahoma’s long-arm statute against the car’s manufacturer, importer, distributor, and retailer, including World-Wide Volkswagen Corp. and Seaway (Defendants), both incorporated in New York. Defendants argued that the Oklahoma court lacked in personam jurisdiction because Defendants did not have sufficient minimum contacts with the state.
May a state court exercise in personam jurisdiction, through a long-arm statute, over a nonresident who made and sold a product outside of the state and are not otherwise connected to the state?
No, the state lacks the minimum contacts required to establish in personam jurisdiction. The lower court’s opinion is reversed.
Justice Brennan argued that the Court failed to properly consider the Oklahoma’s interest in the litigation, the intended use of the car to move between states, and the burden on the Plaintiffs to litigate elsewhere. By balancing these interests, it would be fair and reasonable for the Defendants to litigate in Oklahoma.
The Court determined that the Defendants did not create sufficient minimum contacts with Oklahoma to established in personam jurisdiction. Defendants had no substantial business connection to the state, including having never shipped or sold cars to Oklahoma, run ads in Oklahoma, or sent an agent to Oklahoma. The fact that the Defendants’ product could travel to Oklahoma did not reasonably put Defendants’ on notice of potential litigation in the state.