World-Wide Volkswagen v. Woodson 444 U.S. 286, 100 S. Ct. 559, 62 L. Ed. 2d 490 (1980)
A vehicle purchased in New York by a New York resident (Robinson) was involved in an accident in Oklahoma (as the owner was moving to Arizona and was no longer a New York resident.) Robinson sued the automobile manufacture (Audi), the importer (Volkswagen), the distributor (World-Wide Volkswagen) and the retailer (Seaway) in Oklahoma district court claiming product liability. World-Wide and Seaway entered a special appearance in Oklahoma and claimed that under the Due Process clause of the 14th Amendment, Oklahoma did not have jurisdiction. o Neither World-Wide nor Seaway do business in Oklahoma. District Court ruled that they did indeed have jurisdiction in this case, and that World-Wide could be sued in Oklahoma court. o Audi and Volkswagon chose not to appeal. World-Wide responded by petitioning the Oklahoma Supreme Court to issue a writ of prohibition to the District Judge (Woodson) to exercising in personam jurisdiction. o Oklahoma Supreme Court denied the writ of prohibition, stating that Oklahoma had a long arm statute that authorized the jurisdiction. Statute says that "A court may exercise personal jurisdiction over a person who acts directly or by an agent,É causing torturous injury in Oklahoma by an act of omission outside Oklahoma if he regularly does or solicits business in Oklahoma." Court ruled that since cars are mobile, it is certainly foreseeable that one would be driven to Oklahoma, therefore it is reasonable to infer that World-Wide derives income from cars that are from time to time used in Oklahoma. o World-Wide appealed to the US Supreme Court.
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US Supreme Court reversed the decision of the Oklahoma Supreme Court. o US Supreme Court found that a State Court could exercise in personam jurisdiction over a nonresident if there exist "minimum contacts" between the defendant and that State. This protects defendants from the burdens of litigation in a distant state, and acts to insure that States do not reach out beyond the limits imposed on them by their status as coequal sovereigns in a federal system. US Supreme Court recognized that in recent times, most business is conducted across state lines, and the jurisdictional rules have relaxed a bit. However, they explicitly state that this relaxation does not mean that the jurisdictional rules are to be done away with altogether. The US Supreme Court stresses reasonableness. US Supreme Court found "a total absence of affiliating circumstances" between World-Wide and Oklahoma. US Supreme Court found that foreseeability alone has never been a sufficient benchmark for in personam jurisdiction under the Due Process Clause. To rule otherwise would rule that every seller of goods appoints his goods to be his agent for service of process! Another case, Hanson v. Denkla states, "Unilateral activity of those who claim some relationship with a nonresident defendant cannot satisfy the requirement of contact with the State." Hanson v. Denkla also says that a defendant must purposefully avail (aka intentionally avail) himself of the privilege of conducting activities within the State, thus invoking the benefits and protection of its laws. o Two threads in this case: Oklahoma should not tread on the sovereignty of New York. The defendant has a right to be sued in a forum he has accepted. o 5 Factors that must be considered when determining the forum:
Interest of defendant Interest of plaintiff Interest of the State of Oklahoma Convenience of litigants Social Policy o There was a dissent on the US Supreme Court. The dissent argued that the Court did not weigh the strength of the State's interest in the case. The State has a legitimate interest in enforcing its laws and keeping its highway system safe, and the trial can proceed as efficiently in Oklahoma as anywhere else. Dissent also found that it isn't just foreseeable that an automobile will leave the state it was purchased in, it is intended to leave the state! o In Contract Law, you can write into a contract a choice-of-forum clause, which basically says that if you are going to sue, you must sue in a particular state. These are generally enforceable. But World-Wide Volkswagon did not have this clause in their sales contract. o Btw, if you are a plaintiff's lawyer, you want all possible defendants in the room at the same time, that way they will blame each other and make your case for you. Not having all the defendants in the room allows the ones you are currently suing to blame the guy that you aren't currently suing. Although the arguments for this case were all related to personal jurisdiction, this case was really about diversity and subject matter jurisdiction. The Robinsons' wanted to sue in State Court, not in Federal Court. For that to happen, they need to have one defendant from the same State that they are from (to stop the defendants from using diversity to force the case into Federal Court). They didn't really care about the dealership in particular, it was Volkswagon's deep pockets that really mattered. But since the Robinsons were still technically domiciled in New York, having a defendant in New York would force the case into State Court. o Even though the diversity turned on both the plaintiff and the defendant being from New York, this would still go into an Oklahoma State Court. o This was possibly because the Robinsons' attorneys knew that the local Oklahoma courts were more sympathetic and paid out more money than Federal Courts did. It could also be because the Robinsons' attorneys were more familiar with the State Court
system and the judges.