World-Wide Volkswagen Corp. v. Woodson – Case Brief Summary
Summary of World-Wide Volkswagen Corp. v. Woodson, 444 U.S. 286, 100 S. Ct. 559, 62 L. Ed. 2d 490 (1980).
The plaintiffs in the underlying action were the Robinsons. This part of the case involves a request for a writ of prohibition brought by the defendants (Word-Wide Volkswagen and Seaway) against the trial court judge, Woodson.
The Robinsons (P) purchased an Audi from Seaway Volkswagen, Inc. (D1), a New York car dealership. One year later while driving through Oklahoma, another car hit them from behind, causing a fire which caused severe injuries to Mrs. Robinson and her two children.
The Robinsons brought a products liability suit in state court against four parties including Seaway and its distributor, World-Wide Volkswagen Corp. (Ds). The defendants were New York corporations and conducted no business in Oklahoma. The defendants entered special appearances claiming that Oklahoma could not exert in personam jurisdiction over them by virtue of the Due Process Clause of the Fourteenth Amendment. The trial court found that it had jurisdiction and the Oklahoma Supreme Court denied defendants’ request for a writ of prohibition to restrain the trial judge from exercising in personam jurisdiction over them. The U.S. Supreme Court granted cert.
- In order to exercise personal jurisdiction over a nonresident party, how extensive must the party’s contacts be to satisfy due process?
Holding and Rule (White)
- The party’s contacts with the state must be such that maintenance of the suit does not offend traditional notions of fair play and substantial justice. The relationship between the party and the state must be such that it is reasonable to require the corporation to defend the particular suit which is brought there.
A state court may exercise personal jurisdiction over a party only if the party has minimum contacts with the forum state (see International Shoe Co. v. Washington). The court held that there was a total absence of circumstances that are necessary to permit an exercise of personal jurisdiction. The defendants did not solicit business in Oklahoma through salespersons or advertising reasonably calculated to reach the state.
Although it was foreseeable that one of their cars could be involved in an accident in Oklahoma, foreseeability alone is not sufficient for personal jurisdiction under the Due Process Clause. The degree of foreseeability that must exist is not the mere likelihood that a product will find its way into the state, but that the defendant’s conduct and connection with the state are such that he should reasonably anticipate being haled into court there. Purposeful availment provides clear notice of jurisdiction.
States may exercise jurisdiction over a defendant even if that party has not deliberately or purposefully sought contact with the state. It would be difficult to believe that the defendants truly believed that none of the cars they sold would ever leave the New York area. Their contacts with Oklahoma were not extensive but it was reasonable for them to be subjected to jurisdiction. Fairness dictates that the sale of a mobile item such as a car should satisfy the minimum contacts necessary for jurisdiction.
Jurisdiction here is based on the deliberate and purposeful acts of the defendants in choosing to become part of a global network for marketing and servicing cars. They must have anticipated that a substantial portion of the cars sold would travel to remote states. The probability that some of the cars would eventually get to all contiguous states is a virtual certainty. This knowledge would alert a reasonable businessman to the likelihood that a defect might manifest itself in the forum state.
It is the nature of the instrumentality that is critical. With our network of interstate highways, the defendants could not have believed that their cars would remain in the vicinity of their retail sale. It is not unreasonable, unconstitutional, or beyond International Shoe to uphold jurisdiction in this instance.
See Hanson v. Denckla for a law school civil procedure case brief in which the Supreme Court held that lack of personal jurisdiction over an indispensable party required reversal of the judgment against all parties including those for which exercise of personal jurisdiction was proper.