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World Wide Volkswagen Corp v. Woodson

Law Dictionary

Law Dictionary

Featuring Black's Law Dictionary 2nd Ed.
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Civil Procedure Keyed to Yeazell

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Bloomberg Law

Citation. 444 U.S. 286, 100 S. Ct. 559, 62 L. Ed. 2d 490, 1980 U.S. 65

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.

Facts. Harry and Kay Robinson purchased an Audi automobile from Seaway Volkswagen, Inc. in New York State in 1976. The following year they left New York to move to Arizona. While they were driving through Oklahoma, another car struck them, causing a fire which burned Kay Robinson and two of her children. The Robinsons brought a products liability suit in Oklahoma claiming that their injuries resulted from defective design and placement for the Audi’s gas tank and fuel system. The Robinsons joined as defendants the auto manufacturer, Audi, its importer, Volkswagen of America, Inc., its regional distributor, World Wide Volkswagen Corporation, and its retail dealer, Seaway. The court found that World Wide was incorporated and had its business office in New York. It distributed Vehicles, under Contract with Volkswagen, to retail dealers in New York, Connecticut, and New Jersey. Seaway is a retail dealer whose place of business is in New York. There was no evidence that either World-Wide or Seaway did any business in Oklahoma, shipped or sold any products in that state, had an agent to receive process there, or advertised in Oklahoma. Seaway and World-Wide made special apperances for the purpose of opposing jurisdiction in Oklahoma. The Oklahoma court denied their motion and this appeal followed, whereby the Supreme Court of the United States granted Seaway and World-Wide a writ of certiorari.

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?

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