World-Wide Volkswagen Corp. v. Woodson

444 U.S. 286 (1980)

Yeazell, p. 119-126


Facts: Somebody bought a car from a car dealership in New York. They got into a car accident in Oklahoma where the fuel tank exploded. They started a product liability suit against the present appellants and others in Oklahoma.


Procedural Posture: The car dealer and regional distributor put in a special appearance to argue that Oklahoma did not have jurisdiction under the Due Process Clause of the Fourteenth Amendment. The Supreme Court of Oklahoma denied their writ and the appellants went to the U.S. Supreme Court.


Issue: Can a state court exercise in personam jurisdiction over a nonresident corporation when the only connection between the defendants and the forum is that the car they sold in their state got into an accident in the forum state?


Rule: In order for a state court to exercise in personam jurisdiction over a defendant, there must exist minimum contacts between the defendant, forum, and claim.


Analysis: The court finds that the contacts between the defendant and the forum are not sufficient to sustain jurisdiction. They argue that if they allow the defendants to stand trial in Oklahoma for problems with their car, anyone that sells anything will have to be subject to jurisdiction anywhere that the products might go.


Justice Brennan dissents, making an argument that states’ rights and plaintiffs’ rights are being inappropriately underweighted against defendants’ rights. Brennan argues that cars have a special status among products because it’s expected that they will move themselves into other jurisdictions. Finally, Brennan cites changes in insurance, transportation and communications which make it relatively easy and inexpensive for any defendant to appear in virtually any forum.


Conclusion: The court rules that the appellants have no contacts with Oklahoma and thus it reverses the judgment of the Supreme Court of Oklahoma.


Notes and Problems



a.      Only World-Wide and Seaway were before the Court.

b.     Presumably, Audi and Volkswagen advertise in Oklahoma and sell cars in Oklahoma. Therefore they would be subject to jurisdiction in Oklahoma.

c.     I believe the Massena retailer will not be subject to personal jurisdiction in Oklahoma for the same reasons cited in the present case. However, both the distributor and manufacturer will be subject to jurisdiction because they both do business in Oklahoma, or in other words, they “serve the market” there.

2.     It doesn’t seem inevitable that there should be lawsuits both in Oklahoma and New York. It would seem that the plaintiff could file in federal court instead and name all the defendants in one fell swoop. Also, the court system in general doesn’t seem to find multiple lawsuits undesirable: “Sue first, ask questions later.”

a.      So if the problem is a design fault, the manufacturer is liable.

b.     This might be seen as burdensome to the dealer and distributor since they would be defending two different suits at once.

3.     Maybe there is a diminishing marginal cost of suing more and more parties. That is, once you have a lawsuit going against two parties, the cost of adding two more is relatively low. The text suggests that they didn’t sue the driver of the other vehicle because that driver probably didn’t have much money.

a.      So here, it’s confirmed that he didn’t have insurance, so the best you could do is personally bankrupt him.

b.     So they were going for the big bucks. To do so, it was desirable to keep the case in state court rather than federal court. They argued that the Robinsons were still New York residents, and so they wouldn’t make it under diversity jurisdiction in federal court if they were suing Seaway and World-Wide.

c.     I would expect that the defendants would move to dismiss for lack of personal jurisdiction, and it would seem that the motion must be granted. If that failed for some reason, I suppose they would try to move the trial to federal court.

4.     It seems to make sense that you should be able to join any party that is substantively responsible for the bad act.


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