Master Supreme Court limits personal jurisdiction by holding that mere foreseeability a product will travel to a forum is insufficient absent purposeful availment and minimum contacts. with this comprehensive case brief.
World-Wide Volkswagen v. Woodson is a cornerstone of modern personal jurisdiction doctrine. It clarifies that due process requires more than the mere likelihood that a product will wander into a forum state; it requires that a defendant have purposefully established contacts with the forum such that it could reasonably anticipate being haled into court there. The decision refines International Shoe Co. v. Washington by centering purposeful availment and distinguishing between mere foreseeability of product travel and foreseeability of litigation in a particular forum.
The case also sketches what became known as the stream-of-commerce idea, recognizing that jurisdiction may be proper where a manufacturer or distributor seeks to serve a forum market. Yet it draws a sharp line protecting local retailers and regional distributors from being sued wherever a customer happens to take a product. For law students, the case is essential to understanding minimum contacts, foreseeability, and the federalism and fairness interests that cabin state court power.
444 U.S. 286 (U.S. Supreme Court 1980)
Harry and Kay Robinson, New York residents, purchased a new Audi automobile from Seaway Volkswagen, Inc., a New York retail dealer. The sale was facilitated by World-Wide Volkswagen Corp., a regional distributor for Audi and Volkswagen in the New York, New Jersey, and Connecticut area. Neither Seaway nor World-Wide was incorporated or had offices in Oklahoma; neither was licensed to do business there, had agents there, advertised there, shipped goods there, or otherwise targeted the Oklahoma market. While the Robinsons were driving to Arizona, another car struck their Audi in Oklahoma, allegedly causing a fuel-system fire that injured Kay Robinson and the couple’s children. The Robinsons filed suit in an Oklahoma state court against Seaway (the retailer), World-Wide (the regional distributor), Volkswagen of America, Inc. (the national importer), and Audi NSU Auto Union Aktiengesellschaft (the German manufacturer), alleging product defects. Seaway and World-Wide moved to quash service for lack of personal jurisdiction. The Oklahoma trial court denied the motion, and the Oklahoma Supreme Court denied a writ of prohibition, reasoning that it was foreseeable the car would be used in Oklahoma and that the defendants derived substantial revenue from the sale of automobiles that could be used in many states. Seaway and World-Wide sought and obtained U.S. Supreme Court review on due process grounds.
Whether the Due Process Clause permits an Oklahoma court to exercise specific personal jurisdiction over a New York retailer and a New York regional distributor whose only connection to Oklahoma is that a vehicle they sold in New York was involved in an accident in Oklahoma after the purchaser unilaterally drove it there.
Under International Shoe, a forum may exercise personal jurisdiction over a nonresident defendant only if the defendant has minimum contacts with the forum state such that maintaining the suit does not offend traditional notions of fair play and substantial justice. The critical foreseeability is not that a product may enter the forum, but that the defendant's conduct and connection with the forum are such that it should reasonably anticipate being haled into court there. The unilateral activity of a third party cannot satisfy the requirement of contact with the forum. A state does not exceed its powers if it asserts jurisdiction over a defendant that delivers products into the stream of commerce with the expectation they will be purchased in the forum, but mere foreseeability of a product's travel, without purposeful availment, is insufficient.
No. Oklahoma lacked personal jurisdiction over Seaway and World-Wide. The assertion of jurisdiction violated due process because those defendants had no purposeful contacts with Oklahoma and could not reasonably anticipate being haled into court there.
The Court, per Justice White, began with the minimum contacts framework of International Shoe and Hanson v. Denckla. Seaway and World-Wide had no offices, property, agents, advertising, or sales in Oklahoma, and they were not licensed to do business there. Their only connection to Oklahoma was the fortuity that a customer drove the car there and had an accident. That unilateral activity of the consumer cannot create the necessary forum contacts for the defendants. The Court rejected the Oklahoma Supreme Court's reliance on general foreseeability that a product might travel. The relevant foreseeability for due process is whether the defendant's purposeful conduct makes it reasonable to anticipate being haled into court in the forum state. The Court recognized that jurisdiction may be constitutionally proper where a manufacturer or distributor places products into the stream of commerce with the expectation they will be purchased in the forum. In such circumstances, the sale in the forum would arise from the defendant's efforts to serve that market. But Seaway and World-Wide did not serve, directly or indirectly, the Oklahoma market; their distribution network and activities were confined to the tri-state area. Extending jurisdiction based solely on the mobility of the product would effectively subject every local retailer to suit in every state, contrary to due process and federalism interests. Although the Court noted the fairness factors that inform the reasonableness of jurisdiction when minimum contacts exist (burden on the defendant, forum state's interest, plaintiff's interest in convenient and effective relief, the interstate judicial system's interest in efficient resolution, and the shared interests of the several States), it emphasized that those factors cannot override the threshold requirement of purposeful forum-related contacts. In any event, Oklahoma's interest here was attenuated: the plaintiffs were not Oklahoma residents and the alleged negligence in sale and distribution occurred in New York. Accordingly, exercising jurisdiction over Seaway and World-Wide would offend traditional notions of fair play and substantial justice. The judgment was reversed as to those defendants. The Court did not decide jurisdiction over the manufacturer and national importer, who were not petitioners and whose forum-directed activities might present a different analysis.
World-Wide Volkswagen crystallizes the purposeful availment requirement and the proper understanding of foreseeability in personal jurisdiction. It protects defendants from being haled into distant forums based solely on the unilateral actions of consumers and the inherent mobility of products. The case also plants the seed for the stream-of-commerce analysis, later elaborated in Asahi and J. McIntyre, and frames the reasonableness factors that Burger King formally operationalizes. For law students, it is a go-to authority for minimum contacts, foreseeability, and the limits of state judicial power grounded in due process and federalism.
The Court draws a distinction between foreseeability that a product might end up in a forum and foreseeability of being haled into court there. Only the latter matters for due process. That foreseeability turns on whether the defendant purposefully created a substantial connection with the forum, not on the mere mobility or national use of the product.
World-Wide acknowledges that a state may exercise jurisdiction over a defendant who places products into the stream of commerce with the expectation they will be purchased in the forum. However, the Court found no such expectation or market-targeting by the New York retailer and regional distributor, who did not serve the Oklahoma market. Later cases like Asahi and J. McIntyre debate what additional conduct, if any, is needed to show such expectation.
The Court recognized fairness factors, but it emphasized that they are considered after establishing purposeful minimum contacts. Because Seaway and World-Wide lacked any forum-directed contacts, the Court did not rely on a balancing of interests to salvage jurisdiction.
Likely yes. If the distributor or retailer deliberately targeted Oklahoma through advertising, direct shipments, a dealer network extending into Oklahoma, or other market-serving conduct, those purposeful contacts could make it reasonable to anticipate being sued there, satisfying minimum contacts for specific jurisdiction.
Specific jurisdiction. The question was whether Oklahoma could exercise jurisdiction over claims arising from or related to the defendants' contacts with the forum. There were no continuous and systematic ties to support general jurisdiction, and the claim did not arise from any purposeful Oklahoma-directed conduct by the retailer or regional distributor.
Burger King builds on World-Wide by clarifying that once purposeful contacts exist, courts assess reasonableness factors. Ford Motor Co. emphasizes a flexible relatedness standard and shows that where a defendant extensively serves a forum market, jurisdiction may exist even if the exact product was not first sold there. But World-Wide still bars jurisdiction absent purposeful forum contacts.
World-Wide Volkswagen v. Woodson sets a durable limit on state court jurisdiction by insisting on purposeful, forum-directed conduct. It teaches that due process protects defendants from suits in distant forums based solely on the travels of their products and the unilateral actions of consumers. The case ensures that foreseeability in the personal jurisdiction context is tied to litigation risk that a defendant should reasonably anticipate, not to product mobility.
For students and practitioners, the decision remains a foundational guidepost. It frames the minimum contacts inquiry, anchors the purposeful availment requirement, and foreshadows the stream-of-commerce debates that follow. When analyzing personal jurisdiction, start with World-Wide's core lesson: without purposeful contacts with the forum, courts cannot proceed to reasonableness or fairness balancing, and jurisdiction must be denied.