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''World-Wide Volkswagen Corp v. Woodson'', is a famous United States Supreme Court case involving strict products liability, personal injury and various procedural issues and considerations. The case is best known as an element of the basic Civil Procedure course at nearly every American law school, focusing on the Personal Jurisdiction issues, which were decided by the Supreme Court in a 1980 decision by Justice White. BACKGROUND Robinsons were in an accident; claimed a product defect in the car led to the injuries sustained. They brought suit against automobile’s manufacturer (Audi), its importer (Volkswagen), its regional distributor (World-Wide), and its retailer dealer (Seaway). The latter two claim that Oklahoma’s exercise of jurisdiction over them would offend the limitations on the State’s jurisdiction imposed by the Due Process Clause of the Fourteenth Amendment. The petitioners are fully independent corporations whose relationship with each other and Volkswagen and Audi are contractual only. The Respondents adduced no evidence that either respondent does any business in Oklahoma, ships or sells any product to or in that State, has an agent to receive process there, or purchases advertisements in any media calculated to reach Oklahoma. District Court rejected their constitutional claim, and reaffirmed that ruling in denying petitioners’ motion for reconsideration. ISSUE Whether these particular petitioners were subject to the jurisdiction of the Oklahoma Courts? DECISION The Due Process Clause of the 14th Amendment limit the power of a state court to render personal jurisdiction against a nonresident defendant; due process requires that the defendant be given adequate notice of the suit (non issue in present case). A state court may exercise personal jurisdiction over a nonresident only so long as there exists ‘minimum contacts’ between the defendant and the forum state. The 14th Amendment provides protection against inconvenient litigation, typically described in terms of “reasonableness” or “fairness”. “Does not offend ‘traditional notions of fair play and substantial justice.” The relationship between the defendant and forum must be “reasonable.” The burden on the defendant is to be balanced against other factors, including the plaintiff’s interest in obtaining convenient and effective relief. The Due Process Clause “does not contemplate that a state may make binding a judgment in personam against an individual or corporate defendant with which the state has no contacts, ties or relations.” Even if the defendant would suffer minimal or no inconvenience form being forced to litigate before the tribunals of another State; even if the forum State has a strong interest in applying its law to the controversy; even if the forum State is the most convenient location for litigation, the Due Process Clause may sometimes act to divest the State of its power to render a valid judgment. Petitioners contentions are correct- no minimum contacts there, avail themselves of none of the privileges or benefits of Oklahoma law- No jurisdiction Counterclaim: Foreseeability- Car is mobile; therefore it could lead to an injury in Oklahoma. Majority rejects this- foreseeability (that the product will find its way into the forum State) is not the criterion- However, foreseeability that the defendant’s conduct and connection with the Forum State are such that he should reasonably anticipate being haled into court there, is critical to due process analysis Must be foreseeable that D could be hauled to forum – WWVW: stream of commerce only extends to D’s expectation that product will be purchased by consumer of forum state. EXTERNAL LINKS |
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