World-Wide Volkswagen Corp. v. Woodson

Case brief summary

Facts

A family bought a car in New York, then got badly burned in a crash while driving through Oklahoma. They sued the dealer and distributor there, even though those companies only sold cars in New York, New Jersey, and Connecticut.

Procedural history

Oklahoma courts ruled they could hear the case, saying it was foreseeable a car might end up there. The distributor and dealer asked the U.S. Supreme Court to review that decision.

Issue

Can an Oklahoma court make a New York car distributor and dealer defend a lawsuit there when their only link to Oklahoma is that a car they sold got into an accident while passing through the state?

Holding

No. The Due Process Clause of the Fourteenth Amendment, which limits how far a state can reach with its courts to keep things fair, does not allow Oklahoma to exercise jurisdiction over these defendants.

Reasoning

The dealer and distributor had no offices, sales, or advertising in Oklahoma. Foreseeability that a car might travel there wasn't enough. The company's own actions must connect it to the state for a lawsuit to be fair.

Opinions

Majority (White): The distributor and dealer had no real connection to Oklahoma beyond a customer driving the car there, so Oklahoma courts cannot make them defend the lawsuit.

Dissent (Brennan): The majority focuses too much on the defendant's contacts and ignores Oklahoma's strong interest in the case and the lack of real burden on the defendants.

Dissent (Marshall, joined by Blackmun): The distributor and dealer purposely joined a nationwide car market and network, so they should have expected lawsuits in states like Oklahoma where their cars predictably traveled.

Dissent (Blackmun): Since cars are made to travel long distances, it is not unfair to let Oklahoma hear the case against the distributor and dealer just as it can against the manufacturer and importer.