World Wide Volkswagen v. Woodson

1. World Wide Volkswagen v. Woodson Prof. Dr. John JA Burke Case Brief

2. The Parties Harry and Kay Robinson Kay Robinson and 2 children injured [burned] in car accident World-Wide Volkswagen Corp. NY Corporation, with its head office NY, that served as regional distributor for Volkswagen of America, Inc. by contractual agreement Regions were NY, NJ and Ct. Volkswagen of America, Inc. Importer for Audi NSU Auto Union, A.G. Audi NSU Auto Union, A.G. Manufacturer of Audi and German Corporation, parent of Volkswagen Seaway A new York corporation located in Massena NY and a retailer of Volkswagen products

3. Key Facts The Robinson family, while resident in NY, purchased a new Audi from Seaway in NY in 1976 One year later, they relocated to Arizona While traveling to Arizona, they passed through the State of Oklahoma In Oklahoma, the Robinson car was rear-ended by another vehicle, causing the fuel tank to explode and resulting in severe burns to Ms Robinson and her 2 children Seaway purchased the Audi from World-Wide Neither Seaway nor World-Wide did any business in Oklahoma

4. Procedural History Robinsons brought product liability action against: Audi NSU Auto Union, A.G. Volkswagen of America, Inc. World-Wide Seaway Claiming that faulty design and placement of fuel tank was �cause� of their injuries Action was brought in the District Court for Creek County, Oklahoma Oklahoma asserted in personam jurisdiction over all defendants, and rejected the arguments of World-Wide and Seaway that such assertion of jurisdiction violated their 14th Amendment rights

5. Procedural History World-Wide and Seaway appealed the decision to the Supreme Court of Oklahoma asking the Court to issue a writ of prohibition against Judge Woodson [hence name of case] to stop him from asserting jurisdiction over them The Oklahoma Supreme Court, relying on its Long Arms Statute, denied the petition, maintaining that the statute authorised the exercise of in personam jurisdiction over these defendants Rationale Cars are mobile; easy to foresee their use in other States, including Oklahoma; evidence showed that goods sold by petitioners were used in Oklahoma; therefore, exercise of jurisdiction was reasonable The US Supreme Court granted certiorari to review

6. Key Legal Principles Due Process Clause of 14th Amendment limits power of State Court to render a valid judgment over a non-resident defendant A judgment that contravenes the 14th Amendment is unenforceable Due Process requires: Notice of suit Exercise of personal jurisdiction predicated on �minimum contracts� Protection of non-resident defendants from burdens of litigating in foreign jurisdiction Fidelity to interstate Federalism Sovereignty of each State implies a limitation upon the Sovereignty of all sister States Framers of Constitution never intended to efface territoriality while seeking a common market

7. Underlying Rationale Technological developments render it fairly easy to litigate in a foreign jurisdiction Commercial transactions have continent-wide repercussions An emergence of a single national commercial market seamless and integrated Balancing factors Back to limits of sovereignty Protection of non-residents from state�s overreaching in their exercise of jurisdiction Non-residents must do something more than just engage in commerce; they must purposely avail themselves of the foreign jurisdiction

8. Analysis Applying legal principles and related rationales, court found Oklahoma lacked �affiliating circumstances� with non-resident defendants to exercise jurisdiction over them Supporting Facts Did not do business [sell, repair] in Oklahoma Did not advertise in Oklahoma Did not seek to do business in Oklahoma Limited activities to tri-state area Theory rejected Foreseeability Obvious that car sold anywhere in US could be driven into any other State Foreseeability alone not enough If so, non-resident defendants would/might minimise risks through insurance, passing off costs to consumers Structure conduct differently

9. Conclusion No contacts, no relations, no jurisdiction World-Wide and Seaway cannot be sued in Oklahoma