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World-Wide Volkswagen Corp. v. Woodson

Supreme Court of the United States · 1980 · Civil Procedure

Civil Procedurepersonal jurisdictionminimum contactsstream of commercepurposeful availmentpersonal jurisdictionminimum contactsdue process

Facts

The Robinsons bought a new Audi from Seaway, a New York retailer, and later, while moving from New York to Arizona, were rear-ended in Oklahoma, where the car caught fire and allegedly caused severe burns. They sued the manufacturer, importer, regional distributor World-Wide, and retailer Seaway in Oklahoma state court. World-Wide was a New York corporation distributing vehicles only to dealers in New York, New Jersey, and Connecticut, and Seaway was a New York dealer with its place of business in New York. The record showed no evidence that either World-Wide or Seaway did business in Oklahoma, shipped or sold products there, advertised there, had an agent there, or had any car enter Oklahoma other than the Robinsons' vehicle.

Issue

Whether, consistent with the Due Process Clause of the Fourteenth Amendment, Oklahoma could exercise in personam jurisdiction over a nonresident automobile retailer and wholesale distributor when their only connection to Oklahoma was that a car sold in New York to New York residents was later involved in an accident in Oklahoma.

Rule

Due process permits a state court to exercise personal jurisdiction over a nonresident defendant only when the defendant has minimum contacts with the forum state. Foreseeability alone is insufficient; 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. Jurisdiction is proper when the defendant purposefully avails itself of the privilege of conducting activities in the forum, including where it delivers products into the stream of commerce with the expectation that they will be purchased by consumers in the forum state.

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One of 10 multiple-choice questions for this case. Pick an answer to see why.

Blue Harbor Appliances, a retailer in Syracuse, New York, sells kitchen mixers only from its store and does not advertise, ship, or service products outside New York. Nina Cole bought a mixer there and later moved to Tulsa, Oklahoma, where the mixer allegedly malfunctioned and injured her.

If Nina sues Blue Harbor Appliances in Oklahoma state court, is personal jurisdiction constitutionally proper?

Explanation. Due process requires minimum contacts created by the defendant's own conduct with the forum. The critical foreseeability is not that the product may end up in Oklahoma, but whether the retailer should reasonably anticipate being haled into court there because it served or sought to serve that market. Here, the only Oklahoma connection arises from the buyer's unilateral activity, which is insufficient.