World-Wide Volkswagen Corp. v. Woodson 1980
Personal Jurisdiction > Specific Jurisdiction CivPro – pg96 – 10/27/09
Parties: Π – Injured Drivers ∆ - Car Dealer/Distributors Procedural History: - Case brought in Okla. Where accident occurred - Special appearance by ∆s to quash jurisdiction o Okla SC denied - Writ of certiori granted Facts: - π involved in car accident in Oklahoma - Were driving vehicle purchased from ∆ from NY to Arizona where they were moving - Drunk driver who hit them not in the suit (judgment proof) Legal Issue: Should personal jurisdiction be granted when the only contact to a state is the incidence occurring there? Holding: No. Personal jurisdiction requires the Intntl Shoe test of minimum contacts even when the claim in dispute occurred in that state. Reasoning: - Intnl Shoe purpose: o Protect ∆ from litigating in distant fora o Restrict reach of states - Reasons to allow personal jurisdiction elsewhere o Stat’es interest in adjudicating the dispute o Π interest in convenient and effective relief o Interstate judicial system’s interest in obtaining the most efficient resolution o Shared interest amongst states in furthering fundamental substantive social policies - Personal jurisdiction restrictions have relaxed significantly over time o But they can never overcome the constitutional balance between federalism and statism Even if (x3) other factors suggest otherwise - This case has only the contact of one, isolated occurrence o Just b/c a car could foreseeably be driven to Okla Ø make it a sufficient arg If allowed then “every seller of chattels would in effect appoint the chattel his agent for service of process” and could face trial anywhere Forseeability Ø irrelevant though Allows ∆ to minimally structure conduct based on where they can anticipate litigation Disposition: Reversed Dissent/Concurrence: - Dissent - Brennan o Majority uses intntl shoe too narrowly In fact it may even be outdated o Other factors should be given more weight
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State’s interest ∆ actual inconvenience Autos are designed to be driven around Focusing exclusively on the rights of ∆ is outdated