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World-Wide Volkswagen Corp. v. Woodson

    Brief Fact Summary
    World-Wide Volkswagen (WWV) (Plaintiff) challenged an Oklahoma district court’s (Defendant) in personam jurisdiction in a products liability action brought by Robinson on the grounds that World-Wide Volkswagen’s (Plaintiff) only contacts with Oklahoma was that Robinson bought a World-Wide Volkswagen (Plaintiff) car in New York and drove it through Oklahoma.

    Synopsis of Rule of Law
    A state court may exercise personal jurisdiction over a nonresident defendant only when there exists minimum contacts between the defendant and the forum state.

    Facts
    Robinson bought a World-Wide Volkswagen (WWV) (Plaintiff) car in New York.  While driving to Arizona, Robinson was involved in an auto accident in Oklahoma and brought a products liability action against Plaintiff in Oklahoma.  Plaintiff was incorporated and had its business in New York.  Plaintiff distributed vehicles, parts, and accessories, under contract with Volkswagen, to retail dealers in New York, New Jersey, and Connecticut.  Plaintiff did no business in Oklahoma, had no agents in Oklahoma, did not advertise in Oklahoma, and did not use any media in Oklahoma.  Plaintiff challenged the Oklahoma court’s (Defendant) in personam jurisdiction over Plaintiff on the grounds that Plaintiff had no minimum contacts with Oklahoma.  The district court (Defendant) and the Oklahoma Supreme Court rejected Plaintiff’s challenge.  Plaintiff appealed to the United States Supreme Court.

    Issue
    May a state court exercise personal jurisdiction over a nonresident defendant only when there exists minimum contacts between the defendant and the forum state?

    Held
    (White, J.)  Yes.  A state court may exercise personal jurisdiction over a nonresident defendant only when there exists minimum contacts between the defendant and the forum state.  There are two purposes this minimum contact requirement serves:  (1) It protects the defendant against the burdens of litigating in an inconvenient forum; and (2) It ensures that the states, through their courts, do not reach out beyond the limits imposed on them by their status as coequal sovereigns in a federal system.  Plus, the Due Process Clause, acting as an instrument of interstate federalism, may sometimes divest a state of its power to render a valid judgment.  In this case, Plaintiff did not have minimum contacts with Oklahoma.  Plaintiff’s only contact with the state was that one of its cars had been driven through the state.  It would not be reasonable to expect Plaintiff to foresee that an accident would occur in Oklahoma and have to defend actions wherever their cars are taken.  This situation is distinguished from those where a nonresident corporation intentionally avails itself of the state’s commerce by introducing a product to the state’s market and can therefore fall within the state’s in personam jurisdiction.  In such a situation, the corporation can foresee that litigation might occur in the availed state.  However, in the present case, Plaintiff’s only contact with Oklahoma was that s consumer drove a car through the state.  Since such a contact is not sufficient to satisfy the minimal contacts requirement, the Oklahoma court (Defendant) does not have in personam jurisdiction over WWV (Plaintiff).  Reversed.

    Dissent
    (Brennan, J.)  WWV’s (Plaintiff) contacts to Oklahoma were strong in that the accident occurred in the state, witnesses lived in the state, and the state has a legitimate interest in preserving its interstate highways.  The sale of automobiles presupposes that such cars will be driven to distant states.  This is equal to introducing a product into the market of a state and the likelihood of litigation in other states is foreseeable.  Therefore, WWV (Plaintiff) had sufficient contacts with Oklahoma for jurisdiction to apply.

    Discussion
    The minimum contacts test was first established in International Shoe Co. v. Washington, 326 U.S. 310 (1945).  The test is vague and always requires a detailed examination of the facts.  The court looks at factors such as manifest state interests, purposeful availment, foreseeability, fairness, and states’ long-arm statutes.


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