World-Wide Volkswagen Corp. v. Woodson (1980) (car crash in OK, jurisdiction not found)

a.       Facts- P bought a car from D in NY. P then traveled across the country. During said travel, P’s car got into an accident an in Oklahoma. P then brought suit in an OK Ct against D for product liability. D challenged OK’s personal jurisdiction over D.

b.      Procedural History- Trial Ct found for P, P appealed to U.S. Sup Ct on personal jurisdiction basis

c.       Issue- Whether an OK Ct can exercise personal jurisdiction over a non-resident business (person) in a suit, when the only connection said person has with OK is that a car it sold in NY has traveled to OK

d.      Holding- No, OK Ct’s cannot exercise in personam jurisdiction over a non-resident person where the person’s ONLY connection is the fact that it sold a car in NY that eventually made its way to OK

                                                              i.      Dissent-

1.      International Shoe “minimum contacts” is outdated. Now people can travel across the country in hours; the “inconvenience” to D’s is almost gone and D’s products can be anywhere in the country in the matter of hours

2.      Cars are intended to travel across States therefore dealers foresee sufficient “contact” with other States

3.      We need to distinguish between commercial and personal affairs when determining Jx

4.      Since hospitalization, accident, evidence, and witnesses were all in OK, OK forum would be MOST practical place

e.       Rule- A consumer’s “unilateral” act of bringing a company’s products in a certain State does NOT allow that certain State to exercise personal jurisdiction over a D

f.       Rationale-

                                                              i.      D did NOT make use of or enjoy OK laws, so why should they answer to OK laws?

                                                            ii.      They do NOT advertise in OK or reasonably think ANY of their advertisements will reach OK

                                                          iii.      POLICY: If we allow somebody to sue in the State which they bring the chattel to, then in effect we are saying that the company has appointed an agent of process in its chattel

1.      Ex. Ability to be served travels with the sold chattel

                                                          iv.      “Foreseeability” is not a sufficient measure to apply the Due Process Clause….just because we can foresee cars moving from State to State does NOT mean that Ct’s can exercise jurisdiction over a dealer in EVERY State

g.      Notes:

                                                              i.      Businesses should contemplate whether their products will sufficiently establish contact with other States. If so, they should curb the risk by way of insurance or sever all ties with State completely.

                                                            ii.      3 things must be analyzed when considering personal Jx in accordance to the Due Process Clause:

1.      Inconvenience for the D

2.      Inconvenience for the P

3.      State’s interest in having its own law resolve the controversy

                                                          iii.      “Stream of commerce”- through commercial interaction, a product is bought into another State

                                                          iv.      Why didn’t they sue in Federal Ct?

1.      Because no Federal question was presented

2.      No diversity Jx (with Seaway and World-Wide)

                                                            v.      Minimum contacts of D v. State sovereignty (reasonable and fairness)---balance these factors

1.      State sovereignty gives the State the ability to have its own judicial system

2.      The Ct is balancing the interest of D against the interest of a State

3.      OK has an interest in this case

                                                          vi.      The majority said that there wasn’t “continuous and systematic contact”