Law School Case Brief
World-Wide Volkswagen Corp. v. Woodson - 444 U.S. 286 (1976)
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 concept of minimum contacts, in turn, can be seen to perform two related, but distinguishable, functions. It protects the defendant against the burdens of litigating in a distant or inconvenient forum. And it acts to ensure that the States, through their courts, do not reach out beyond the limits imposed on them by their status as coequal sovereigns in a federal system.
Plaintiffs Kay Eloise Robinson, E.M.R, a minor, and Harry Robinson, who were residents of New York, were injured in an automobile accident that occurred in Oklahoma. Thereafter, they filed a products liability action in Oklahoma state court against defendants World-Wide Volkswagen Corporation and Seaway Volkswagen, which were the distributor and retailer, respectively, of the automobile the Robinsons were driving at the time of the accident. Defendants, which were incorporated in New York and did business there, entered a special appearance in the litigation, asserting that Oklahoma's exercise of jurisdiction over them would offend the limitations on state jurisdiction imposed by the due process clause of the Fourteenth Amendment. The trial court rejected the due process claim. Defendants then sought a writ of prohibition in the Supreme Court of Oklahoma to restrain the trial judge, respondent Honorable Charles S. Woodson, from exercising in personam jurisdiction over them. The writ was denied on the ground that personal jurisdiction was authorized by a provision of Oklahoma's "long-arm" statute. That statute authorized an Oklahoma court's exercise of in personam jurisdiction over a person who caused tortious injury in Oklahoma by an act or omission outside Oklahoma if that person regularly did or solicited business or engaged in any other persistent course of conduct, or derived substantial revenue from goods used or consumed or services rendered in Oklahoma. Defendants were granted a writ of certiorari.
Did the Oklahoma court's exercise, under its long-arm statute, of in personam jurisdiction over defendants violate due process?
The Supreme Court of the United States reversed the Supreme Court of Oklahoma's judgment denying defendants' petition for a writ of prohibition. The Court held that a state court could exercise personal jurisdiction over a nonresident defendant only so long as there existed minimum contacts between the defendant and the forum state. The defendant's contacts with the forum state must be such that maintenance of the suit did not offend traditional notions of fair play and substantial justice, and the relationship between the defendant and the forum must be such that it was reasonable to require the defendant to defend the particular suit which is brought there. In the instant case, the Court ruled, there was a total absence in the record of those affiliating circumstances that were a necessary predicate to any exercise of state-court jurisdiction. Defendants carried on no activity whatsoever in Oklahoma; they closed no sales and performed no services there, availed themselves of none of the benefits of Oklahoma law, and solicited no business there either through salespersons or through advertising reasonably calculated to reach that state.
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