World-Wide Volkwagen Corporation v. Woodson (1979)
- Docket
- 78-1078
- Decided
- 1979-01-01
Summary
Question: May a state court exercise in personam jurisdiction over a non-resident defendant in a products liability action where the defendant’s only connection to the state is the accident in question? Conclusion: No. In a 6-3 decision, Justice Byron R. White wrote the majority opinion reversing the lower court judgment. The Supreme Court held that a state court could only exercise in personam jurisdiction over a non-resident defendant when that defendant has “minimum contacts” with the state. In this case, the only contact with Oklahoma was the accident. The Volkswagen retailer and distributor had taken advantage of none of the benefits of Oklahoma law, had not solicited business in Oklahoma, and did not regularly sell cars that reached Oklahoma directly or indirectly. Justice William J. Brennan wrote a dissent expressing the view that the retailer and distributor had purposely entered their goods into the stream of commerce and had gained benefits from other states through the nature of their product. Justice Thurgood Marshall wrote a dissent, stating that a local car retailer makes itself a part of a national network of retailers and can reasonably expect that its product may cause injury in other states. Justice Harry A. Blackmun wrote a dissent stating that cars were intended for local and long-distance travel, so it was not unreasonable for Oklahoma to exercise jurisdiction when the accident happened there.