Civil Procedure I, Pages 103–109

World-Wide Volkswagen Corp. v. Woodson

Supreme Court of the United States, 1980

Facts:

Plaintiffs purchased a new Audi automobile from defendant Seaway Volkswagen in New York. The next year the plaintiffs left New York to move to Arizona. While in transit in Oklahoma, another car struck their Audi in the rear, causing a fire with severely burned one of the plaintiffs and her two children. Plaintiffs then brought a products-liability lawsuit in the district court for that county in Oklahoma, claiming that their injuries were a result of defective design. Defendants have no business operation in Oklahoma and there is no record of one of their cars even traveling through that state before.

Procedural History:

The trial court found for the plaintiff. Petitioners sought a writ of prohibition in the Supreme Court of Oklahoma to restrain the District Judge from exercising in personam jurisdiction over them, which the court denied as it was reasonably foreseeable that the vehicle could be used in that state given its mobile nature.

Issue:

Does it violate due process for a state court to exercise in personam jurisdiction over a nonresident automobile retailer and its wholesale distributor in a products-liability action when the defendants' only connection to the state is that an automobile they made was involved in a crash there?

Rules:

  • Foreseeability that a product may be used in a state is not enough minimal contact to gain in personam jurisdiction in that state.

  • The defendant should be able to reasonably anticipate being haled into court.

Reasoning:

Foreseeing that a product one makes may be used in a state is not enough for that state to have jurisdiction over him because such an act violates the state's sovereignty of its citizens who have had no minimal contact there.

Holding:

Yes, exercising jurisdiction over a nonresident manufacturer is a violation of due process even if it was foreseeable that the product was going to be used in the state. The defendant should also be able to reasonably anticipate being haled into court.

Takeaway:

Foreseeability that a product may be used in a state is not enough minimal contact to gain in personam jurisdiction in that state.

Keepa – Amazon Price Tracker