World-Wide Volkswagen Corp. v. Woodson
Supreme Court of the United States, 1980
444 U.S. 286, 100 S.Ct. 559, 62 L.Ed. 2d 490.
Facts: The Robinsons bought a car in New York. A year later they moved to Arizona. On the way, in Oklahoma, they got rear-ended which started a fire that severely burned Kay Robinison and the children. The Robinsons brought a product-liability action in the District Court for Creek County, OK against the World-Wide Volkswagen (among others).
Procedure: The current plaintiff tried to get the trail judge of the Robinson case to admit that there was no jurisdiction over them under the Due Process clause. When the judge refused, they sought a writ of prohibition from the Supreme Court of Oklahoma. The supreme court denied, and so they appealed.
Issue: Does the Due Process clause of the Fourteenth amendment allow for in personam jurisdiction in a case where the only connection to the location is that the accident happened there?
Holding: No.
Reasoning: There are no contacts with the state and the mere "forseeability" of one of it's products passing through it is not enough.
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1 comment:
You missed the point. The point is that it wasn't foreseeable that they'd be haled into court in that state. Not that their product would pass through. As a motor vehicle, it's quite foreseeable that it'd pass through.
However, by only selling vehicles in/around NY, they weren't willfully availing themselves to law in that state, and therefore could not reasonably foresee being haled into court there.
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