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World-Wide Volkswagen Corp. v. Woodson
World-Wide Volkswagen Corp. v. Woodson
Personal Jurisdiction
capable of use in Oklahoma is far too attenuated a contact to justify the states
exercise of in personam jurisdiction over them.
The court examined the Reasonableness Factors: (Even if the reasonableness
factors support
jurisdiction, there can be no jurisdiction without minimum
contacts)
o Burden on Defendant
o States interest in adjudicating the dispute
o Plaintiffs interest in obtaining convenient and effective relief
o Interstate judicial systems interest in obtaining most efficient resolution of
the controversy
o The shared interest of the several states in furthering fundamental
substantive social policies
Holding:
Because the court could not find that petitioners had any contacts, ties, or
relations, with the state of Oklahoma, the judgment of the Supreme Court of
Oklahoma is REVERSED.
Dissent:
Brennan reasoned that the courts opinions focus tightly on the existence of
contacts between the forum and the defendant. He contends that they did not
place enough weight on the strength of the forum states interest in the case
without exploring the possibility of any actual inconvenience to the defendant.
Brennan argued that the state has a legitimate interest in enforcing its laws
designed to keep its highway system safe, and the trial can proceed just as
efficiently in Oklahoma as anywhere else. The very purpose of an automobile is
for it to be mobile. Brennan asserted that someone in the business of selling cars
cannot plead ignorance of their mobility and that they had to anticipate the
possibility of the vehicle entering a state outside their limited territory of
business. Brennan claims that the courts opinion suggests that the defendant
can only be subject to a states jurisdiction if has contact with the state such that
he should reasonably anticipate going there. Brennan further argued that if the
plaintiff can prove actual injury and the defendant couldnt show some real injury
to a constitutionally protected interest, there is no excuse why he shouldnt
appear.