World-Wide Volkswagen Corp. v. Woodson
62 L. Ed. 2d 490 · Supreme Court of the United States · 1980
Facts
New York residents purchased an Audi automobile from a New York retailer and distributor. While driving through Oklahoma, the car was involved in an accident, causing severe injuries. The injured parties sued the New York retailer and distributor in Oklahoma, alleging defective design, despite the defendants having no business contacts with Oklahoma.
Issue
Can an Oklahoma court exercise in personam jurisdiction over a nonresident automobile retailer and its wholesale distributor, consistent with the Due Process Clause, when their only connection with Oklahoma is that a car they sold in New York to New York residents was involved in an accident there?
Holding
No, the Supreme Court reversed the Oklahoma Supreme Court's decision, holding that Oklahoma courts could not exercise in personam jurisdiction over the nonresident automobile retailer and distributor.
Rule
The Due Process Clause requires that a nonresident defendant have 'minimum contacts' with the forum state, such that they have 'purposefully availed' themselves of the privilege of conducting activities within that state. Mere foreseeability that a product might enter a state, or the unilateral activity of a consumer, is not sufficient to establish personal jurisdiction.
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