Worldwide Volkswagen Corp. vs. Woodson

Worldwide Volkswagen Corp. vs. Woodson

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Worldwide Volkswagen Corp. vs. Woodson

Plaintiff and Defendant:

The plaintiff in this case is Woodson. The defendants were the German manufacturer of the Audi Automobile, Volkswagen of America (the importer), World-Wide Volkswagen (the wholesale distributor), and Seaway (the retail dealership).

Facts:

The plaintiff Woodson is a resident of the state of New York and purchased a vehicle, an Audi, from the Seaway Dealership in the State of New York. The plaintiff Woodson was injured while in Oklahoma, which was caused by a defect in the car. The plaintiff sued the dealership and the other defendants to recover personal injuries in an Oklahoma State court. All defendants were served under he long-arm statute. The dealership and importer objected to the Oklahoma court’s personal jurisdiction.

Lower Courts:

The Oklahoma courts rejected the defendants’ arguments that it did not have jurisdiction over this case and found all defendants liable for the plaintiff’s injury. The U.S. Supreme Court granted the petitions for certiorari filed by Seaway and World-Wide Volkswagen.

Issue Appealed:

Whether the State of Oklahoma may exercise jurisdiction over two New York corporations in a liability case related to product when the only connection the defendants have with Oklahoma is that a vehicle sold to a New York resident in the state of New York was involved in an accident. The accident happened in the state of Oklahoma.

Who Wins:

Seaway (the dealer) and World-Wide Volkswagen (the wholesale distributor) win.



Reasoning:

1. The Due Process Clause of the Fourteenth Amendment limits the power of a state court to render a valid personal judgment against a non-resident defendant. A state may exercise personal jurisdiction over a non-resident defendant only so long as there exist “minimum contacts” between the defendant and the state.
2. This standard protects the defendant from having to defend themselves in an inconvenient or distant place. It further ensures that states will not overstep its boundaries that were and contradict he balances set forth by the federal government system.
3. World-Wide Volkswagen and Seaway demonstrate that there are limits to the exercise of personal jurisdiction over non-resident defendants. The decision recognizes that companies manufacture goods movable in interstate commerce and that any particular good can settle in diverse physical locations. Although the manufacturer knows that the product is movable, such as a car, that awareness alone is inadequate to provide a basis for the exercise of personal jurisdiction by a remote foreign court; thus they cannot be sued in that state.

Case Questions:

1. In determining personal jurisdiction, what factors did the court assess in the relationship among the defendant, the forum, and the litigation?

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"Worldwide Volkswagen Corp. vs. Woodson." 123HelpMe.com. 21 Feb 2020
    <https://www.123helpme.com/view.asp?id=125353>.

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“A state court may exercise personal jurisdiction over a nonresident defendant only as long as there exist ‘minimum contacts’ defendant and the forum state. The defendant’s contacts with the forum state must be such that maintenance of the suit ‘does not offend ‘traditional notion of fair play and substantial justice.’”
2. What single factor influenced the Court the most in reaching its decision in this case? The fact that the defendants have no “’contacts, ties, or relations’ with the State of Oklahoma,” thus the judgment of the Supreme Court of Oklahoma was reversed.
3. Let’s assume that parties from different states entered into a contract. What aspects of the relationship would be most important in determining personal jurisdiction over an out-of-state party if a lawsuit was filed claiming breach of contract? The fact that both parties are well aware that they are performing business across state lines.
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