ProfessorBrittany L. Raposa
CaseCast™ – "What you need to know"
Brief Fact Summary. A family that purchased a car in New York sued the auto manufacturer and retailer after they became involved in an accident in Oklahoma while driving to Arizona.
Synopsis of Rule of Law. A consumer’s unilateral act of bringing the defendant’s product into the forum state is not a sufficient basis for exercising personal jurisdiction over the defendant.
Even if the defendant would suffer minimal or no inconvenience from being forced to litigate before the tribunals of another State; even if the forum State has a strong interest in applying its law to the controversy; even if the forum State is the most convenient location for litigation, the Due Process Clause, acting as an instrument of interstate federalism, may sometimes act to divest the State of its power to render a valid judgment.View Full Point of Law
Issue. Whether an Oklahoma court may exercise in personam jurisdiction over a non- resident automobile retailer and its wholesale distributor in a products liability suit, when the defendants’ only connection with Oklahoma is the fact that an auto sold in New York to New York residents became involved in an accident in Oklahoma?
Held. No. The Supreme Court reversed the Oklahoma court’s ruling. Forseeability of being asked to defend a suit in a particular forum is not a sufficient benchmark for personal jurisdiction under the Due Process Clause. Instead, it is the defendant’s conduct and connection with the forum state that determines whether it is reasonable for a defendant to be haled into court. Because Seaway and World-Wide had no contacts, ties or relations with the state of Oklahoma, jurisdiction would violate the Due Process Clause.
Dissent. Justice Brennan dissented. He found that the court’s over-reliance on contacts between the defendant and the state obscures whether being subject to a suit there would actually cause any inconvenience to the defendant. Additionally, he found that because the interest in having the suit in Oklahoma was strong, given that the plaintiffs were hospitalized there and key witnesses resided there, jurisdiction should have been granted. A dissenting opinion by Justice Marshal, joined by Justice Blackmun, was omitted by the casebook editors.
Discussion. The court’s reasoning for not extending jurisdiction is that the two purposes of the minimum contacts requirement, i.e. protecting defendants against the burden of litigating in a distant forum and ensuring that State courts do not reach beyond the limits established by the federal system, would not be served if jurisdiction were granted. Specifically, the court relied on the fact that Seaway and World-Wide carry on no activity whatsoever in Oklahoma, perform no services there, and avail themselves of none of the privileges and benefits of Oklahoma law. The court will look not to whether it was foreseeable to the defendant that he could be sued in a given state, but whether a suit there is reasonable given the defendant’s ties and relations with the state.