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 Robinsons moved to Arizona. While driving to Arizona, the Robinsons were struck by another vehicle in Oklahoma. The Robinsons’ car burst into flames, severely burning Kay Robinson and her children. While hospitalized in Oklahoma, the Robinsons filed a products-liability suit in Oklahoma state court against multiple parties, including Seaway and World-Wide Volkswagen (World-Wide) (defendant), a vehicle distributor that operated in New York, New Jersey, and Connecticut and had provided the Robinsons’ car to Seaway. The Robinsons claimed that their vehicle caught fire because of the defective design of its fuel system. Seaway and World-Wide made a special appearance in the trial court, arguing that asserting personal jurisdiction over them would violate the Fourteenth Amendment’s Due Process Clause because they were not located in Oklahoma, did not do any business in Oklahoma, and did not advertise to Oklahoma residents. When the trial court disagreed, Seaway and World-Wide sought a writ of prohibition in the Oklahoma Supreme Court to stop trial judge Charles Woodson from asserting 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.