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The foreseeability that is critical to due process analysis is not the mere likelihood that a product will find its way into the forum state. Rather, it is that the defendant's conduct and connection with the forum state are such that he should reasonably anticipate being haled into court there.
New York residents purchased a new car from petitioner retailer. While driving through Oklahoma to a new home in Arizona, the purchasers' car was struck in the rear by another vehicle, causing a fire, which severely injured them. The purchasers brought a products-liability action in an Oklahoma court against petitioners, among others. Petitioners, which were incorporated in New York and did business there, entered special appearances, claiming that, because they had no minimal contacts with the state, Oklahoma's exercise of jurisdiction over them would violate their rights under the Due Process Clause of U.S. Const. amend. XIV. The Oklahoma trial court rejected petitioners' claim, and petitioners sought a writ of prohibition in the Oklahoma supreme court to restrain respondent, a state trial judge, from exercising in personam jurisdiction over them. The state supreme court denied the writ, holding that personal jurisdiction was authorized by Oklahoma's long-arm statute, Okla. Stat. tit. 12, § 1701.03(a)(4) (1971).
Could the Oklahoma trial court exercise in person jurisdiction over petitioner retailer?
On certiorari, the United States Supreme Court reversed. The court held that under the rule that a state court may exercise personal jurisdiction over a nonresident defendant only so long as there exist minimum contacts between the defendant and the forum state, the Oklahoma trial court could not, consistently with the due process clause of the Fourteenth Amendment, exercise in personam jurisdiction over the New York automobile retailer and wholesale distributor, since the only connection between Oklahoma and such defendants--who closed no sales and performed no services in Oklahoma, who availed themselves of none of the privileges and benefits of Oklahoma law, who solicited no business in Oklahoma either through salespersons or through advertising reasonably calculated to reach Oklahoma, and who did not regularly sell cars at wholesale or retail to Oklahoma customers or residents or indirectly, through others, serve or seek to serve the Oklahoma market--was the fortuitous circumstance that a single automobile, sold by the defendants in New York to New York residents, happened to suffer an accident while passing through Oklahoma.