World-Wide Volkswagen Corp. v. Woodson

New York residents Harry and Kay Robinson (plaintiffs) purchased a car from Seaway Volkswagen (Seaway) (defendant), a New York automobile retailer. The next year, the Robinson family moved to Arizona. While driving to Arizona, the Robinsons were struck by another car in Oklahoma. The Robinsons’ car caught fire, severely burning Kay Robinson and her children. The Robinsons brought a products-liability suit in Oklahoma state court against multiple parties, including Seaway and World-Wide Volkswagen (World-Wide) (defendant), a northeast regional vehicle distributor that had supplied the Robinsons’ car to Seaway. The Robinsons claimed that the fire resulted from the defective design of the car’s fuel system. Seaway and World-Wide made a special appearance in the trial court, arguing that Oklahoma’s exercise of personal jurisdiction over Seaway and World-Wide would violate constitutional due process because the companies were not located in Oklahoma, did not do any business in Oklahoma, and did not advertise to Oklahoma residents. The trial court disagreed, holding that it could exercise personal jurisdiction over Seaway and World-Wide. Seaway and World-Wide then sought a writ of prohibition in the Oklahoma Supreme Court to stop trial judge Charles Woodson from exercising personal jurisdiction over them. The Oklahoma Supreme Court denied the writ, approving personal jurisdiction because it was foreseeable that Seaway’s and World-Wide’s automobiles might be used in Oklahoma. The United States Supreme Court granted certiorari.