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World-Wide Volkswagen Corp. v. Woodson

(1980)

Supreme Court of the United States - 444 U.S. 286, 100 S. Ct. 559

tl;dr:

The personal Jurisdiction minimum contacts test over a non-resident defendant is re-defined to require reasonable foreseeability of being subject to suit in a state.

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Case Summary

In the 1980 case World-Wide Volkswagen Corp. v. Woodson, the US Supreme Court dealt with a family who experienced injuries in a car accident in Oklahoma, while driving from New York to Arizona. They sued car maker Audi, importer Volkswagen of America, distributor World-Wide Volkswagen, and retailer Seaway Volkswagen for the faulty design and location of the car's gas tank and fuel system. The defendants argued that the Oklahoma court had no jurisdiction over them, as they had insufficient connections to the state.

The Supreme Court agreed with World-Wide Volkswagen and Seaway Volkswagen, ruling that state courts can only exercise personal jurisdiction over out-of-state businesses if they have "purposefully availed" themselves of the state's laws and protections. The Court also stated that causing injury in another state is not enough to establish jurisdiction unless the defendant also has meaningful ties to that state.

This case was significant because it expanded upon the minimum contacts test for personal jurisdiction, as established in International Shoe Co. v. Washington. It also clarified the difference between specific jurisdiction (based on the defendant's lawsuit-related activities) and general jurisdiction (based on the defendant's continuous, systematic connections to the state). The case has since influenced developments in personal jurisdiction doctrine.

ICRAIssue, Conclusion, Rule, Analysis for World-Wide Volkswagen Corp. v. Woodson

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Facts & HoldingWorld-Wide Volkswagen Corp. v. Woodson case brief facts & holding

Facts:The Robinson family (residents of New York) bought a car...

Holding:The simple fact that WWV injected their products into the...

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World-Wide Volkswagen Corp. v. Woodson | Case Brief DeepDive
Majority opinion, author: Mr. Justice White
Level 1
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The case involves determining whether an Oklahoma court can exercise jurisdiction over a nonresident automobile retailer and its wholesale distributor in a products-liability action. The Supreme Court of the United States reversed the decision of the Supreme Court of Oklahoma, stating that the Due Process Clause of the Fourteenth Amendment limits the power of a state court to render a valid personal judgment against a nonresident defendant. Personal jurisdiction over nonresidents requires "minimum contacts" between the defendant and the forum state. The burden on the defendant will be considered in light of other relevant factors, including the forum state's interest in adjudicating the dispute, the plaintiff's interest in obtaining convenient and effective relief, the interstate judicial system's interest in obtaining the most efficient resolution of controversies, and the shared interest of the several states in furthering fundamental substantive social policies. The Due Process Clause acts as an instrument of interstate federalism, and territorial limitations on the power of respective states are the reason for these restrictions.

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Dissenting opinion, author: Me. Justice Brennan
Level 1
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Justice Brennan dissents from the Court's decision that the Due Process Clause of the Fourteenth Amendment prohibits the States from asserting jurisdiction over the defendants in these two cases due to the lack of "minimum contacts" required since International Shoe Co. v. Washington. Justice Brennan believes that the Court's interpretation of International Shoe and its progeny is too narrow and that the standards set by those cases may no longer be constitutional boundaries. The focus should be on fairness and reasonableness, rather than a mechanical test based solely on the quantity of contacts. The existence of some contacts is just one factor in determining fairness and reasonableness. The interests of the State and other parties involved in the case are such factors. The case involves a personal injury lawsuit filed by a Minnesota resident, which is suitable for trial in Minnesota due to the state's interest in providing a forum for its residents and regulating insurance companies. The defendant's burden in defending the case in Minnesota is minimal, as the real impact is on the defendant's insurer, which is amenable to suit in the forum state. The defendant is only a nominal party who need not be more active in the case than the cooperation clause of his policy requires. Adding the defendant's name to the complaint does not violate due process, as the real impact on the defendant is the same as in a direct action against the insurer, which is constitutionally permissible.

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Dissenting opinion, author: Mr. Justice Marshall
Level 1
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The dissenting opinion in the case argues that the majority's application of the constitutional standard for determining state-court jurisdiction is too restrictive. The Due Process Clause requires a defendant to have minimum contacts with the forum state to be subject to a judgment in personam. However, a more comprehensive view of the defendant's conduct may justify the exercise of jurisdiction, as the defendants intentionally and deliberately promoted and maintained vehicles both nationally and internationally. The court notes that the argument in favor of jurisdiction is not solely based on "foreseeability," but also on the fact that the petitioners knowingly caused effects in other states and received economic advantage from the activities of dealers and distributors in those states.

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Dissenting opinion, author: Mr. Justice Blackmun
Level 1
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The dissenting opinion in this case questions why the regional distributor and retail dealer are being named as defendants, when the manufacturer and importer should also be held liable. The peripatetic nature of automobiles is emphasized, making it unrealistic to expect a new car to remain in the vicinity of its retail sale. The jurisdiction of Oklahoma over a New York distributor and dealer is not unreasonable, as all parties involved in the distribution and sale of vehicles are in the business of providing vehicles that travel across state lines. The Court declares that the distinction between foreseeable use in another state and foreseeable resale in another state is determinative.

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