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World-Wide Volkwagen Corp. v. Woodson
444 U.S. 286 (1980)
CERTIORARI TO THE SUPREME COURT OF OKLAHOMA
MR. JUSTICE WHITE delivered the opinion of the Court.
The issue before us is whether,
consistently with the Due Process Clause of the Fourteenth Amendment,
an Oklahoma court may exercise in personam jurisdiction over a nonresident automobile retailer and its wholesale distributor in a products liability action, when the defendants' only connection with Oklahoma is the fact that an automobile sold in New York to New York residents became involved in an accident in Oklahoma.
D sold the car at NY to NY residents but accident was occurred at Oklahoma
I
Respondents Harry and Kay Robinson purchased a new Audi automobile from petitioner Seaway Volkswagen, Inc. (Seaway), in Massena, N.Y. in 1976. The following year, the Robinson family, who resided in New York, left that State for a new home in Arizona. As they passed through the State of Oklahoma, another car struck their Audi in the rear, causing a fire which severely burned Kay Robinson and her two children.
(When they passed through Oklahoma another car struck their Audi.)
The Robinsons subsequently brought a products liability action in the District Court for Creek County, Okla., claiming that their injuries resulted from defective design and placement of the Audi's gas tank and fuel system.
Respondents brought a PL suit in the District Ct.
They joined as defendants the automobile's manufacturer,
Audi NSU Auto Union Aktiengesellschaft (Audi); its importer,
Volkswagen of America, Inc. (Volkswagen); its regional distributor, petitioner World-Wide
They joined the defendants
manufacturer Audi,
importer Volkswagen,
distributor WW or Works Corp, Seaway (special appearances)
Volkswagen Corp. (World-Wide); and its retail dealer, petitioner Seaway. Seaway and World-Wide entered special appearances, claiming that Oklahoma's exercise of jurisdiction over them would offend the limitations on the State's jurisdiction imposed by the Due Process Clause of the Fourteenth Amendment.
II
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.
Kulko v. California Superior Court, 436 U. S. 84, 436 U. S. 91 (1978).
(It seems to me this is where the term “personal” jurisdiction originated from, i.e., plaintiff’s personal preference over the jurisdiction subsequent ratification of the court)
A judgment rendered in violation of due process is void in the rendering State and is not entitled to full faith and credit elsewhere.
Pennoyer v. Neff, 95 U. S. 714, 95 U. S. 732-733 (1878).
(Exclusive jurisdiction and Sovereignty )
Due process requires that the defendant be given adequate notice of the suit,
Mullane v. Central Hanover Trust Co., 339 U. S. 306, 339 U. S. 313-314 (1950),
and be subject to the personal jurisdiction of the court,
International Shoe Co. v. Washington, 326 U. S. 310 (1945).
In the present case, it is not contended that notice was inadequate; the only question is whether these particular petitioners were subject to the jurisdiction of the Oklahoma courts.
We have said that the defendant's contacts with the forum State must be such that maintenance of the suit "does not offend traditional notions of fair play and substantial justice.'"
International Shoe Co. v. Washington, supra at 326 U. S. 316, quoting Milliken v. Meyer, 311 U. S. 457, 311 U. S. 463 (1940).
The relationship between the defendant and the forum must be such that it is "reasonable . . . to require the corporation to defend the particular suit which is brought there."
326 U.S. at 326 U. S. 317.
Implicit in this emphasis on reasonableness is the understanding that the burden on the defendant, while always a primary concern, will in an appropriate case be considered in light of other relevant factors, including the forum State's interest in adjudicating the dispute,
see McGee v. International Life Ins. Co., 355 U. S. 220, 355 U. S. 223 (1957);
the plaintiff's interest in obtaining convenient and effective relief, see Kulko v. California Superior Court, supra at 436 U. S. 92,
at least when that interest is not adequately protected by the plaintiff's power to choose the forum,
cf.
Shaffer v. Heitner, 433 U. S. 186, 433 U. S. 211, n. 37 (1977);
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,
see
Kulko v. California Superior Court, supra at 436 U. S. 93, 436 U. S. 98.
D's contacts with the forum State must be such that maintenance of the suit "does not offend traditional notions of fair play and substantial justice.'"
means, specifically, it consider
D’s burden and forum State’s interest
P’s interest
Interstate judicial system’s interest
Shared interest of the several States
The limits imposed on state jurisdiction by the Due Process Clause, in its role as a guarantor against inconvenient litigation, have been substantially relaxed over the years. As we noted in McGee v. International Life Ins. Co., supra
… the requirements for personal jurisdiction over nonresidents have evolved from the rigid rule of Pennoyer v. Neff, 95 U. S. 714, to the flexible standard of International Shoe Co. v. Washington, 326 U. S. 310. But it is a mistake to assume that this trend heralds the eventual demise of all restrictions on the personal jurisdiction of state courts. Those restrictions are more than a guarantee of immunity from inconvenient or distant litigation. They are a consequence of territorial limitations on the power of the respective States."
Thus, the Due Process Clause
"does not contemplate that a state may make binding a judgment in personam against an individual or corporate defendant with which the state has no contacts, ties, or relations."
International Shoe Co. v. Washington, supra at 326 U. S. 319.
Even if the defendant would suffer minimal or no inconvenience from being forced to litigate before the tribunals of another State; even if the forum State has a strong interest in applying its law to the controversy; even if the forum State is the most convenient location for litigation, the Due Process Clause, acting as an instrument of interstate federalism, may sometimes act to divest the State of its power to render a valid judgment.
Hanson v. Denckla, supra at 357 U. S. 251, 357 U. S. 254.
The Due Process Clause
may sometimes divest the State of its power to render a valid judgment over the personam which the state has no contacts, ties, relations.
III
It is argued, however, that, because an automobile is mobile by its very design and purpose, it was "foreseeable" that the Robinsons' Audi would cause injury in Oklahoma. Yet "foreseeability" alone has never been a sufficient benchmark for personal jurisdiction under the Due Process Clause. In Hanson v. Denckla, supra, …
Even though it’s mobile, “foreseeability” alone is not sufficient under the Due Process Clause.
Petitioners, NY distributers, carry on no activity whatsoever in Oklahoma, happened to suffer an accident while passing through Oklahoma.
This is not to say, of course, that foreseeability is wholly irrelevant. But the foreseeability that is critical to due process analysis is not the mere likelihood that a product will find its way into the forum State. Rather, it is that the defendant's conduct and connection with the forum State are such that he should reasonably anticipate being haled into court there.
See Kulko v. California Superior Court, supra at 436 U. S. 97-98;
Shaffer v. Heitner, 433 U.S. at 433 U. S. 216;
and see id. at 433 U. S. 217-219 (STEVENS, J., concurring in judgment).
The Due Process Clause, by ensuring the "orderly administration of the laws," International Shoe Co. v. Washington, 326 U.S. at 326 U. S. 319,
gives a degree of predictability to the legal system that allows potential defendants to structure their primary conduct with some minimum assurance as to where that conduct will and will not render them liable to suit.
The “foreseeability is more than likelihood that a product will find its way into the forum.
The Due Process C gives a degree of predictability…
… it is not unreasonable to subject it to suit in one of those States if its allegedly defective merchandise has there been the source of injury to its owner or to others. The forum State does not exceed its powers under the Due Process Clause if it asserts personal jurisdiction over a corporation that delivers its products into the stream of commerce with the expectation that they will be purchased by consumers in the forum State. Cf. Gray v. American Radiator & Standard Sanitary Corp., 22 Ill. 2d 432, 176 N.E.2d 761 (1961).
If a defective product was delivered to the state, that’s another matter.
It’s foreseeable.
But the mere "unilateral activity of those who claim some relationship with a nonresident defendant cannot satisfy the requirement of contact with the forum State." Hanson v. Denckla, supra, at 357 U.S. 253.
But, here, mere a unilateral activity between the forum and nonresident defendant.
Financial benefits accruing to the defendant from a collateral relation to the forum State will not support jurisdiction if they do not stem from a constitutionally cognizable contact with that State. See Kulko v. California Superior Court, 436 U.S. at 436 U. S. 94-95.
P argued jurisdiction can be supported by the fact that D earn substantial revenue from goods used in Oklahoma. But the “contact” is too attenuated.
BRENNAN, dissenting.
Another consideration is the actual burden a defendant must bear in defending the suit in the forum. McGee, supra. Because lesser burdens reduce the unfairness to the defendant, jurisdiction may be justified despite less significant contacts.
B
… the interest of the forum State and its connection to the litigation is strong. The automobile accident underlying the litigation occurred in Oklahoma. The plaintiffs were hospitalized in Oklahoma when they brought suit. Essential witnesses and evidence were in Oklahoma.
See
Shaffer v. Heitner, 433 U.S. at 433 U. S. 208.
The State has a legitimate interest in enforcing its laws designed to keep its highway system safe, and the trial can proceed at least as efficiently in Oklahoma as anywhere else.
… the seller purposefully injects the goods into the stream of commerce, and those goods predictably are used in the forum State.
Thus, the Court errs in its conclusion that "petitioners have no contacts, ties, or relations’"
MARSHALL with BLACKMUN joins, dissenting.
They must have anticipated, however, that a substantial portion of the cars they sold would travel out of New York. Seaway, a local dealer in the second most populous State, and World-Wide, one of only seven regional Audi distributors in the entire country would scarcely have been surprised to learn that a car sold by then had been driven in Oklahoma on Interstate 44, a heavily traveled transcontinental highway.
It is misleading for the majority to characterize the argument in favor of jurisdiction as one of "foreseeability' alone."
As economic entities, petitioners reach out from New York, knowingly causing effects in other States and receiving economic advantage both from the ability to cause such effects themselves and from the activities of dealers and distributors in other States.
While they did not receive revenue from making direct sales in Oklahoma, they intentionally became part of an interstate economic network, which included dealerships in Oklahoma, for pecuniary gain.
In light of this purposeful conduct, I do not believe it can be said that petitioners "had no reason to expect to be haled before a[n Oklahoma] court."
Shaffer v. Heitner, supra at 433 U. S. 216;
Kulko v. California Superior Court, 436 U. S. 84, 436 U. S. 97-98 (1978).
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