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World-Wide Volkswagen v. Woodson

From lawbrain.com

World-Wide Volkswagen v. Woodson, 444 U.S. 286 (1980), was a civil procedure case heard by the United States Supreme Court concerning in personam jurisdiction over non-resident corporate defendants.

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Contents

Summary of Case Facts

In 1976, the plaintiffs purchased an Audi sedan, a 100 LS, from Seaway Volkswagen, Inc. in Massena, NY. The next year the plaintiffs left New York to move to Arizona. During their trip, their car was struck from behind by a drunk driver, causing enough damage to puncture the gas tank, start a fire, and severely burn the occupants trapped inside. The plaintiffs filed suit in Oklahoma against Volkswagen of America, Seaway Volkswagen, the German parent company – Volkswagen AG, and the regional distributor – World-Wide Volkswagen, alleging liability based on defective product design. This Supreme Court opinion concerns, mainly, the arguments presented by Seaway and World-Wide Volkswagen who sought to restrain the District Judge, respondent Charles S. Woodson, from exercising in personam jurisdiction over them.

Issue

Could the court exercise in personam jurisdiction over the non-resident corporate defendants in a products liability action when their only contact with the state of Oklahoma was the car, involved in the accident, at the heart of this lawsuit?

Holding and Law

No, in order for a court to exercise in personam jurisdiction over a defendant there must be minimum, purposeful contacts between the defendant, forum, and claim as prescribed by International Shoe. Those contacts must significant enough that it would be reasonable to require the party to come to the state to defend itself and such that it would not offend the traditional notions of fair play and substantial justice. As applied to Seaway and World-Wide Volkswagen, the Oklahoma state court could not exercise in personam jurisdiction over them; they had never engaged directly in sales or advertising with the state, and while it could be foreseeable that this car could enter the state of Oklahoma, that alone would not be enough.

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Contributors

FindLaw AHK, FindLaw John, Sfitzpatrick