World-Wide Volkswagen Corp. v. Woodson

Summary

The Supreme Court held that Oklahoma could not exercise personal jurisdiction over a New York automobile retailer and regional distributor whose only connection to Oklahoma was that a vehicle sold in New York was involved in an accident there. The Court concluded that the defendants lacked the minimum contacts, purposeful availment, and affiliating circumstances required by the Due Process Clause of the Fourteenth Amendment. Justice Brennan dissented, emphasizing fairness, the forum state's interests, and the burden of litigation.

Holdings

1. Oklahoma could not constitutionally exercise personal jurisdiction over the nonresident retailer and regional distributor because they had no minimum contacts, ties, or relations with Oklahoma.
2. Mere foreseeability that a product may find its way into the forum State is insufficient; the relevant foreseeability is whether the defendant's conduct and connection with the forum are such that the defendant should reasonably anticipate being haled into court there.
3. Financial benefits accruing from a collateral relationship to the forum do not support personal jurisdiction when they do not stem from a constitutionally cognizable contact with the forum.

Questions Presented

1. Whether Oklahoma could exercise personal jurisdiction over a nonresident automobile retailer and regional distributor whose only connection with Oklahoma was that an automobile sold in New York to New York residents later entered Oklahoma and was involved in an accident there.
2. Whether foreseeability that an automobile might travel to Oklahoma, or alleged revenue from goods used in Oklahoma, satisfies the minimum-contacts requirement of the Due Process Clause.

Disposition

reversed