Harry and Kay Robinson, New York residents, bought a new Audi from Seaway Volkswagen, a New York retailer, through World-Wide Volkswagen, a New York-based regional distributor. While moving to Arizona, the Robinsons were rear-ended in Oklahoma, and the Audi caught fire, causing severe burns. The Robinsons sued Audi, Volkswagen of America, World-Wide, and Seaway in Oklahoma state court on a products-liability theory. World-Wide and Seaway challenged personal jurisdiction, noting they did no business in Oklahoma, had no agents or advertising there, and had no relevant Oklahoma-directed activity beyond the car’s presence in the state during the trip.
Does the Due Process Clause permit Oklahoma courts to exercise personal jurisdiction over a nonresident auto retailer and distributor whose only connection to Oklahoma is that a car they sold in New York was later involved in an accident there?
A state may exercise personal jurisdiction over a nonresident defendant only when the defendant has minimum contacts with the forum such that suit there does not offend traditional notions of fair play and substantial justice. Foreseeability that a product may enter the forum is not enough; the defendant must purposefully avail itself of the privilege of conducting activities within the forum State.
No. Oklahoma’s exercise of jurisdiction over World-Wide Volkswagen and Seaway violated due process because they lacked the requisite minimum contacts with Oklahoma.
The Court stressed that due process protects both fairness to defendants and the structural limits of state sovereignty. World-Wide and Seaway did not sell, ship, advertise, or seek to serve the Oklahoma market, and their only link to Oklahoma was the fortuitous movement of a single car by the purchasers. Mere foreseeability that an automobile might travel to another state does not establish jurisdiction; the relevant foreseeability is whether the defendant’s own conduct and connection with the forum are such that it should reasonably anticipate being haled into court there. Because these defendants had not purposefully availed themselves of Oklahoma, the state lacked authority to assert jurisdiction.
Justice Brennan, joined by Justice Marshall, dissented. He argued that jurisdiction was reasonable given the mobility of automobiles, the defendants’ participation in a nationwide distribution system, Oklahoma’s interest in providing a forum for injuries occurring there, and the reduced burdens of modern interstate litigation.
World-Wide Volkswagen is a foundational modern personal-jurisdiction case. It sharpened the distinction between mere foreseeability and purposeful availment, emphasizing that a defendant’s own forum-directed conduct is essential to specific jurisdiction. The case builds on International Shoe Co. v. Washington, 326 U.S. 310 (1945), and Hanson v. Denckla, 357 U.S. 235 (1958), and it shaped later stream-of-commerce and specific-jurisdiction decisions such as Asahi Metal Industry Co. v. Superior Court of California, Solano County, 480 U.S. 102 (1987), Burger King Corp. v. Rudzewicz, 471 U.S. 462 (1985), and J. McIntyre Machinery, Ltd. v. Nicastro, 564 U.S. 873 (2011).
International Shoe Co. v. Washington, 326 U.S. 310 (1945) |
Verified |
Hanson v. Denckla, 357 U.S. 235 (1958) |
Verified |
Asahi Metal Industry Co. v. Superior Court of California, 480 U.S. 102 (1987) |
Abstain |
Burger King Corp. v. Rudzewicz, 471 U.S. 462 (1985) |
Abstain |
Ltd. v. Nicastro, 564 U.S. 873 (2011) |
Abstain |
Enter a case name or citation — get a structured brief where every case it cites is checked against real law.
Try Law Student Workbench →