World-Wide Volkswagen Corp. v. Woodson

444 U.S. 286 (1980)

Justice WHITE (6-3 opinion)

Facts:

  • In Sept. 1977, an Audi automobile holding Kay Eloise Robinson and her two children was struck in the rear by another car.
  • The gas tank of the Audi ruptured and caused a fire in the passenger compartment, injuring Robinson and her two children 

Procedural History:

  • Mrs. Robinson and her family brought manufacturers products liability actions against WWV and three other defendants.
  • Respondent, Judge Woodson, the trial judge wants to serve petitioner under the Oklahoma Long Arm Statute (OLAS).
  • Petitioner is sought a writ of prohibition to prevent Judge Woodson from exercising personal jurisdiction over them through the OLAS.
  • The court denied the prohibition and concluded that the service process was constitutional
  • Petitioner appeals to the Supreme Court

Reversed

Issue:

Whether consistent with the Due Process Clause of the 14th Amendment, an Oklahoma court may exercise in personam judgment over an out of state corporation in a products liability action when defendant’s only contact with Oklahoma is that their products may be used there.

Holding:

Consistent with the Due Process Clause of the 14th Amendment, an Oklahoma court may NOT exercise in personam judgment over an out of state corporation in a products liability action when defendant’s only contact with Oklahoma is that their products may be used there because the corporation has no “contacts, ties or relations” with Oklahoma.

Rule:

A court can only exercise personal jurisdiction on a corporation that has have “certain minimum contacts with the forum state” beside the use of their products by consumers within the state. A state cannot exercise personal jurisdiction over a person or corporation with which it has no “contacts, ties or relations.”

Reasoning:

* International Shoe Co. v. Washington (1945) established the rule for jurisdiction over corporations by stating that a State court may only exercise personal jurisdiction over a nonresident defendant if that defendant had “minimum contacts” with the State. This

* The “minimum contacts with the State must be reasonable and considered in the light of 3 factors:

  1. The State’s interest
  2. The plaintiff’s interest
  3. The interstate judicial interest

* Even though the economic transformation in the US has led to relaxation of the Due Process Clause, the Court must remain faithful to the principles of the Constitution as well as those of Interstate Federalism, seeing the country as a single “free-trade unit” while at the same time respecting State sovereignty. For this reason, even though the 3 factors enumerated above may be high, a State may be divested of its power to render a valid judgment Hanson v. Dekla.

* This case does not satisfy the 3 factors, and jurisdiction is based on one isolated event and the inferences drawn from it. (WEAK ARGUMENT) p.117-118

* Foreseeability is not sufficient to grant personal jurisdiction under due process, if foreseeability were the criteria, every chattel seller would appoint the chattel its agent for service of procedure and amenability to suit would travel with the chattel. Foreseeability is not irrelevant, it applies to the foreseeability that certain conduct in and ties with a state will anticipate being brought to court in that state.

* If a corporation delivers its products into the stream of commerce with the expectation that they will be purchased by consumers within a State, that State has personal jurisdiction over the corporation. However, these are not the facts of this case. The Court characterizes the Robinson’s accident in Oklahoma as “unilateral activity of those who claim some relationship with a nonresident defendant cannot satisfy the requirement of contact with the forum State” Hanson v. Dekla.

* The lower court’s assertion that WWV derives significant revenue from the possibility that their cars can travel to states like Oklahoma, as evidenced by their network of dealers and service centers, is not enough of a connection to give Oklahoma personal jurisdiction over WWV.

Court’s Order:

Judgment of Oklahoma Supreme Court REVERSED.

Dissent:

Justice BRENNAN

* State interest is high: safe highways, witnesses, hospitalization, etc.

* WWV is connected to the state because WWV’s commercial impact is not limited to NY Tri-state area.

* The car is intended to move around

*WWV purposefully injected its cars into the stream of interstate commerce, therefore they are purposefully availing themselves of those states, and it is foreseeable that they can be hailed into court

* WWV derives significant revenue from Oklahoma from (1) the use of its cars in a network of highways maintained by states including Oklahoma and (2) its network of dealerships and service centers. If this did not exist, WWV would sell less cars.

Justice MARSHAL, Justice BLACKMUN

* The majority’s view of WWV’s forum-related conduct is too narrow, because WWV deliberately became part of a national and global market.

* If it were not for the network of dealerships and service centers (including those in Oklahoma) WWV would not sell as many cars. By becoming part of this network, WWV facilitates and encourages travel to states including Oklahoma.

* As one of only 7 Audi authorized distributors, it is foreseeable that WWV’s products will be used in Oklahoma.

Justice BLACKMUN

The nature of the car is as an instrument of travel, and not limited to the area where it was sold.