World-Wide Volkswagen Corp. v. Woodson, 444 U.S. 286 (1980)
Personal jurisdiction may be appropriate if an out-of-state defendant established contact with the forum state such that it should have reasonably anticipated being brought into court in that state based on its conduct and connection with it.
After buying an Audi in New York, the Robinsons left for a new home in Arizona. They were struck from behind by another car as they traveled through Oklahoma, which caused a fire in which Mrs. Robinson and their children were burned. In the ensuing product liability claim, they argued that Audi was responsible for their injuries because of its faulty placement of its gas tank and fuel systems, which they alleged was a design defect. The family also sued World-Wide Volkswagen Corp., the manufacturer of the car, Volkswagen of American, the regional distributor, and the company that imported the car.
World-Wide had its main office in New York, and it was a New York corporation. Its cars and vehicle components were distributed under its contract with Volkswagen to dealerships in New Jersey and Connecticut as well as New York. Seaway also was a New York corporation that had its main office in New York. Neither of these defendants engaged in business in Oklahoma, sent any of their products there, had an agent there to receive process, or sought to promote their products in that state. They thus appealed a finding in the trial court that it had personal jurisdiction over them on the basis that the accident was foreseeable.
- Byron Raymond White (Author)
- Warren Earl Burger
- Potter Stewart
- Lewis Franklin Powell, Jr.
- William Hubbs Rehnquist
- John Paul Stevens
Minimum contacts between the defendant and the forum state must exist to support personal jurisdiction. Rather than the mere possibility that a product will go into the forum state, foreseeability consists of finding that the defendant's conduct and interactions with the forum state should lead to a reasonable anticipation of being brought into court there. Due process requires that defendants have the opportunity to engage in a course of conduct with some advance knowledge of where they may be brought into litigation. Purposeful availment of the privilege of conducting business in the forum state does create clear notice that a defendant may be sued there. It then may decide to buy insurance, pass costs to consumers, or cease doing business in that state. Since the two defendants do not purposefully avail themselves of the privilege of doing business in the forum state, nor do they engage in any business in that state or seek to target that market, personal jurisdiction is improper.
- William Joseph Brennan, Jr. (Author)
Personal jurisdiction may be found when the litigation has a relationship to the forum state, there is a state interest in allowing it to proceed, and the defendant is not unreasonably burdened. International Shoe (1945) and the ensuing line of cases may not be the appropriate standard anymore, and they should not be so narrowly interpreted. Cars are a type of product that can be easily foreseen to travel among states, and it is reasonable to infer that manufacturers and retailers intend that they should travel among states. Engaging in their sale thus equates to a purposeful availment of interstate commerce. The principles of fair play and substantial justice are not compromised by requiring an automobile retailer to defend a case in any state where that car is involved in an accident.
- Thurgood Marshall (Author)
- Harry Andrew Blackmun
Rather than minimizing their interactions with other states, the two defendants have perceived that they will gain an economic benefit from these interactions and have structured their business in a way that increases that likelihood. The defendants acted purposefully and deliberately in participating in a nationwide and global network for selling and maintaining cars.
- Harry Andrew Blackmun (Author)
Cars foreseeably will be used to travel long distances from where they are originally sold, as shown by the network of interstate highways and the prevalence of out-of-state license plates. The accident involving a product distributed by the defendants occurred in the forum state, so personal jurisdiction is reasonable. However, it may not have been necessary to include them in this case because the forum certainly has jurisdiction over the manufacturer and the importer.Case Commentary
In addition to saving defendants from the burden of litigating in a distant, unrelated forum, the threshold requirements of the minimum contacts standard for personal jurisdiction prevents states from infringing on each other's sovereignty in a way that would undermine federalism.
U.S. Supreme CourtWorld-Wide Volkswagen Corp. v. Woodson, 444 U.S. 286 (1980)
World-Wide Volkswagen Corp. v. Woodson
Argued October 3, 1979
Decided January 21, 1980
444 U.S. 286
A products liability action was instituted in an Oklahoma st,ate court by respondents husband and wife to recover for personal injuries sustained in Oklahoma in an accident involving an automobile that had been purchased by them in New York while they were New York residents and that was being driven through Oklahoma at the time of the accident. The defendants included the automobile retailer and its wholesaler (petitioners), New York corporations that did no business in Oklahoma. Petitioners entered special appearances, claiming that Oklahoma's exercise of jurisdiction over them would offend limitations on the State's jurisdiction imposed by the Due Process Clause of the Fourteenth Amendment. The trial court rejected petitioners' claims, and they then sought, but were denied, a writ of prohibition in the Oklahoma Supreme Court to restrain respondent trial judge from exercising in personam jurisdiction over them.
Held: Consistently with the Due Process Clause, the Oklahoma trial court may not exercise in personam jurisdiction over petitioners. Pp. 444 U. S. 291-299.
(a) A state court may exercise personal jurisdiction over a nonresident defendant only so long as there exist "minimum contacts" between the defendant and the forum State. International Shoe Co. v. Washington, 326 U. S. 310. The defendant's contacts with the forum State must be such that maintenance of the suit does not offend traditional notions of fair play and substantial justice, id. at 326 U. S. 316, and the relationship between the defendant and the forum must be such that it is "reasonable . . . to require the corporation to defend the particular suit which is brought there," id. at 326 U. S. 317. The Due Process Clause
"does not contemplate that a state may make binding a judgment in personam against an individual or corporate defendant with which the state has no contacts, ties, or relations."
(b) Here, there is a total absence in the record of those affiliating circumstances that are a necessary predicate to any exercise of state court jurisdiction. Petitioners carry on no activity whatsoever in Oklahoma; they close no sales and perform no services there, avail
themselves of none of the benefits of Oklahoma law, and solicit no business there either through salespersons or through advertising reasonably calculated to reach that State. Nor does the record show that they regularly sell cars to Oklahoma residents, or that they indirectly, through others, serve or seek to serve the Oklahoma market. Although it is foreseeable that automobiles sold by petitioners would travel to Oklahoma and that the automobile here might cause injury in Oklahoma, "foreseeability" alone is not a sufficient benchmark for personal jurisdiction under the Due Process Clause. The foreseeability that is critical to due process analysis is not the mere likelihood that a product will find its way into the forum State, but rather is that the defendant's conduct and connection with the forum are such that he should reasonably anticipate being haled into court there. Nor can jurisdiction be supported on the theory that petitioners earn substantial revenue from goods used in Oklahoma. Pp. 444 U. S. 295-299.
585 P.2d 351, reversed.
WHITE, J., delivered the opinion of the Court, in which BURGER, C.J., and STEWART, POWELL, REHNQUIST, and STEVENS, JJ., joined. BRENNAN, J., filed a dissenting opinion, post, p. 444 U. S. 299. MARSHALL, J., filed a dissenting opinion, in which BLACKMUN, J., joined, post, p. 444 U. S. 313. BLACKMUN, J., filed a dissenting opinion, post, p. 444 U. S. 317.