World-Wide Volkswagen Corp. v. Woodson

444 U.S. 286, 100 S. Ct. 559 (1980)

 

RULE:

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 hauled into court there.

FACTS:

New York residents purchased a car from a retailer in New York, which was struck in the rear by another vehicle in Oklahoma. The purchasers brought a products-liability action in Oklahoma against the car retailer. The car retailer claimed a violation of its due process and questioned the Oklahoma court’s jurisdiction over them considering they were incorporated in New York and had no minimal contacts with the state of Oklahoma. The trial court rejected this claim, so the car retailer filed a writ of prohibition with the Supreme Court of Oklahoma.The Supreme Court of Oklahoma denied the writ, holding that personal jurisdiction was authorized under state law. The case was elevated on certiorari to the Supreme Court of the United States.

ISSUE:

Can a state acquire personal jurisdiction over a subject that has no contact with the state?

ANSWER:

No.

CONCLUSION:

The Court held that the car retailer had no contacts, ties, or relations with the State of Oklahoma. 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 Due Process Clause does not contemplate that a state may make binding a judgment in personam against an individual or corporate defendant with which the state has no contacts, ties, or relations.

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