C A S E B R I E F

Case Brief: World-Wide Volkswagen Corp. v. Woodson

III. ADJUDICATORY AUTHORITY: THE PARTIES.
A. In Personam Jurisdiction.

NAME: World-Wide Volkswagen Corp. v. Woodson, Supreme Court of the United States (1980).

FACTS:
ß (1976) P Robinson purchased an Audi automobile from D Seaway Volkswagen, Inc. in
Massena, New York.
ß Seaway's wholesale distributor was World-Wide Volkswagen Corp, a company incorporated in
the State of New York, which distributes vehicles, parts and accessories to Volkswagen retailers
in New York, New Jersey and Connecticut.
ß (1977) P and his family were seriously injured when, while passing through the State of
Oklahoma, they were involved in an automobile accident that resulted in a fire due to an
allegedly defective gas tank and fuel system on the Audi.
ß P brought a products liability suit in Oklahoma state court naming, among others, Seaway
Volkswagen, Inc. and World-Wide Volkswagen Corp.

PROCEDURE: P Robinson commenced an action in the District Court for Creek County, Oklahoma and D
entered special appearances and moved to dismiss the complaint against them claiming that
Oklahoma lacked personal jurisdiction over them. The District Court denied Ds’ motion holding
that it did have jurisdiction over the Ds. Ds' subsequent petition to the Supreme Court of
Oklahoma for a writ of prohibition to restrain the District Court from excising jurisdiction over Ds
was also denied. Ds appealed the Oklahoma Supreme Courts' decision denying the writ of
prohibition to the United States Supreme Court.

ISSUE: Whether an Oklahoma court may exercise in personam jurisdiction or a nonresident automobile
retailer and its wholesale distributor in a products-liability action, when the Ds’ only connection
with Oklahoma is the fact that an automobile sold in New York -- to New York residents --
became involved in an accident in Oklahoma?

HOLDING: Because Ds Seaway and World-Wide had no contacts, ties or relations with the State of
Oklahoma, the District Court lacked personal jurisdiction over them.

REASONING: Rule: A state may exercise personal jurisdiction over a nonresident D only so long as there exist
"minimum contacts" between the D and the forum state such that a D should reasonably anticipate
being hailed into court there.

ß Ps offered no evidence that Seaway or World-Wide engaged in any conduct whatsoever in

Oklahoma.
ß Ds did not close any sales, solicit sales perform any services in Oklahoma.
ß Ds did not avail themselves of the privileges and benefits of Oklahoma law.
ß Even though one could argue that it was foreseeable that the car sold to Ps would travel through,
and become involved in an accident in, Oklahoma, a seller's amenability to suit does not travel
with the chattel he sells.

DISPOSITION: United States Supreme Court reversed the judgment of the Supreme Court of Oklahoma.

CLASS NOTES: