World-Wide Volkswagen Corp. v. Woodson


Petitioner: World-Wide Volkswagen Corp. Respondent: Woodson (district judge in Oklahoma), et. Al. (Robinsons, original plaintiffs) Procedural History: Plaintiff sues defendant in Oklahoma district court. Defendants sought writ of prohibition, due to lack of jurisdiction, but it was denied. Petitioners (defendants) granted certiorari and is not before U.S. Supreme court. Facts: Robinsons purchased a car from Seaway (car retailer) in New York. They drove the car in Oklahoma and there were involved in an accident which severely burned wife and children. They were still citizens of NY (motts v perry - you have your old domicile until you establish a new one). Robinsons then brought a product-liability action in a district court in Oklahoma against petitioners, among others. World-Wide Volkswagen Corp. (regional distributor) joined with the petitioner, Seaway and made a special appearance, claiming that Oklahoma does not have jurisdiction over them. They were denied here. Seaway is incorporated in NY, has its primary place of business there, and has primary business dealings with NY, NJ, and CT. Petitioners never had any business in or with Oklahoma, and never set foot there. Also, there no showing that any automobile sold by petitioner ever before entered Oklahoma until this incident. Petitioners sought of writ of prohibition in the Oklahoma Supreme Court, judge Woodson, but this was denied because Oklahoma court said that due to the nature of an automobile, it would should be assumed that it may make its way into Oklahoma. Also car retailers gained profit from selling this vehicle, that was used in Oklahoma. Petitioners then were granted certiorari, and the case is now before the U.S. supreme court. Issue: Is it unconstitutional for Oklahoma to have jurisdiction over a NY corporation that never had any business dealings in Oklahoma, where the suit arises out of a product sold by the corporation and used in Oklahoma? Is there car being used in Oklahoma sufficient as minimum contact in order to have jurisdiction? Holding/Judgment: Finding that petitioners had no contacts, ties, or relations with the State of Oklahoma, the Court reversed the state supreme court's denial of a writ of prohibition. Reasoning: Defendant out to be subject to a state's jurisdiction only if he has contacts with the state, "such that he should reasonably anticipate being haled into court there." Petitioners here had not reason to believe they would be held under Oklahoma's jurisdiction. _________________________________________________________________________________ CLASS NOTES Citizenship requirement of diversity, and removal jurisdiction. (pg 106). Facts here trace exactly facts of Hernandez to defeat removal by naming an instate defendant. Volkswagen, as national distributor could be seen as conducting business in every state. Oklahoma statute says state has jurisdiction over a party in the state, if they derive substantial profit from the business. Pg 102 - supreme court of Oklahoma ruled that it is within their jurisdiction, so

granted certiorari to supreme court f U.S. if the statute is constitutional.

Supreme court of U.S. can only review

What would you argue in support of personal jurisdiction? ○ Its foreseeable that a car would wind up in Oklahoma, and ○ that they gain benefit from a nationwide dealership of this business. By having a network. § He does reach out to Oklahoma, by encouraging ppl to buy from him by the promise that they can go anywhere they like and be serviced by one of their partners (not necessarily that they reached out specifically to the oklahoma market). It's likely that 2 lawsuits would be required, or possible that there is personal jurisdiction in NY. Problem for party due to travel expenses. Solved by federal action, but no jurisdiction. Supplemental jurisdiction still wont solve this problem. If I want to pursue this, very likely to have 2 lawsuits. From the point of view of the defendant, poor local retailer being dragged to Oklahoma. - fail the fairness test. Retailer has no inconvenience because they have an insurance company to deal with this. Oklahoma has interest in this. They care about the safety in their state. Policy of personal jurisdiction so that not just any state can get jurisdiction, but Oklahoma is involved in this. Ex. If you send a child to ca you are not purposeful available to become under CA jurisdiction, because you are not benefitting. No purposeful availment. Don’t want to give too much power to the courts, in general. Def has to engage its action to some predictability. Hypo: if they marketed in Oklahoma.