World-Wide Volkswagen Corp. v. Woodson

444 U.S. 286 (1980)

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Nature of the Case

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Facts

The Robinsons (P) bought a new Audi from Seaway, a New York car dealer. A year later, they drove the car across country to their new home in Arizona. On the way, they had a crash in Oklahoma. Another car hit their Audi in the rear, which resulted in a fire and severely injured Kay Robinson and her two children. D brought a product liability suit in state court in Oklahoma against both Seaway (D1), the dealer, and World-Wide (D2), the regional distributor of the cars and Audi and the national distributor, Volkswagen. Both D1 and D2 were located in New York. They had no office nor did they conduct business in Oklahoma in any manner. The trial court and the Oklahoma Supreme Court rejected the notion that D1 and D2 should not be subjected to jurisdiction in Oklahoma and held jurisdiction over them. They reasoned that Ds should have foreseen the possibility of litigation in Oklahoma given the unique mobile nature of the product they sold. (As part of the factual analysis is it important to know that D1 only claimed to do business in New York and D2 only did business in the tri-state area of New Jersey, New York, and Connecticut. Neither of the Ds employed anyone in Oklahoma, conducted any business in Oklahoma or directed advertising at the Oklahoma marketplace). The Supreme Court granted certiorari.