World-Wide Volkswagen v. Woodson
444 U.S. 286, 100 S. Ct. 559, 62 L. Ed. 2d 490 (1980)

  • Robinson bought a car in New York while he was a New York resident. As he was moving to Arizona (so he was no longer a New York resident) he was involved in an accident in Oklahoma.
  • 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.
      • Neither World-Wide nor Seaway did business in Oklahoma.
  • The Trial Court found that they did have jurisdiction in this case, and that World-Wide could be sued in Oklahoma court. World-Wide appealed.
    • Audi and Volkswagon chose not to appeal.
  • The Oklahoma Supreme Court affirmed. World-Wide appealed.
    • The Oklahoma Supreme Court found that Oklahoma had a long arm statute that authorized the jurisdiction.
      • “A court may exercise personal jurisdiction over a person who acts directly or by an agent, causing torturous injury in Oklahoma by an act of omission outside Oklahoma if he regularly does or solicits business in Oklahoma.”
    • The Court found 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.
  • US Supreme Court reversed.
    • The 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.
    • The Court noted that since the advent of cars, most business is conducted across state lines, and the jurisdictional rules have relaxed a bit. However, this relaxation does not mean that the jurisdictional rules are to be done away with altogether.
    • The Court found “a total absence of affiliating circumstances” between World-Wide and Oklahoma.
    • The Court found that foreseeability alone is not enough to create minimum contacts necessary for in personam jurisdiction.
  • In a dissent it was 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.
  • Five 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
  • Btw, 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.
  • 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.