World-Wide Volkswagen Corp v. Woodson
SCOTUS - 1980 (444 U.S. 286)
- Robinsons purchased an Audi from D (Seaway Volks) in NY.
- Following year, Robinsons moved to AZ, passing through OK where they were in an accident. Car caught on fire.
- Robinsons sued auto manufacturer, importer, regional distributor, and retail dealer in OK.
- Regional distributor (World-wide Volks) and retail dealer (Seaway Volks) are the parties in this case about jurisdiction.
- D lost in District Court.
- D lost appeal in Supreme Court of OK.
- D won appeal in SCOTUS, OK has no jurisdiction.
- Can a forum state exercise in personam jurisdiction over a party when that party's only connection with that forum state is that some of the products distributed/sold by that party were involved in a tortuous act in that state?
- A forum state can exercise in personam jurisdiction over a party whose conduct and connection with the forum state are such that he should reasonably anticipate being haled into court there.
- Jurisdiction may be exercised if a party delivers its products into the "stream of commerce" with the expectation that they will be purchased by consumers in the forum state.
- The mere "unilateral activity" of a party who claims some relationship with the nonresident defendant is not enough to satisfy the requirement of minimum contact in a forum state.
- Ds had no sales and performed no services in OK. They avail themselves to none of the privileges and benefits of OK law. Thus, there was no way to establish the D had minimum contacts with OK.
- The foreseeability that is critical to due process analysis is not the mere likelihood that a product will find its way into a forum state. It is that the Ds conduct and connection with the forum state are such that he should reasonably anticipate being haled into court there.
- If foreseeability were the only criteria, "Every seller of chattels would in effect appoint the chattel his agent for service of process."
- Even if the D would suffer minimal or no inconvenience from being forced to litigate in a particular state and even if the forum state is the "best" place for litigation, DP can still deprive that state of taking jurisdiction over a case.
- Jurisdiction should be valid in this case because the purposeful and deliberate actions of the Ds in choosing to become part of a nationwide network for marketing and servicing cars.
- Jurisdiction should be valid if a product enters a state in the course of its intended use by the consumer.
- If the burden to the D is not unreasonable and if the forum state has an interest in allowing the litigation, it should be permitted to do so.
- Minimum contacts must exist "among the parties, the contested transaction, and the forum state".
- Because of changes in transportation since Shoe, the constitutional concepts of fairness no longer require the extreme concern for Ds as was once necessary.
- The dealership and distributor receive no benefit if vehicles are driven into OK.
- The P wanted the case to stay in state court, so that's the main reason the distributor and dealership were added to the complaint.
- The appellee in this case is a judge because the Ps did a writ of prohibition against the judge that ruled against them in jurisdictional issues.
- The court only had a problem with the "minimum contacts" test, not with the "fair play and substantial justice" test