World-Wide Volkswagen Corp. v. Woodson

Facts

In 1976 Harry and Kay Robinson bought a new Audi from Seaway Volkswagen, Inc., a dealer in Massena, New York. The next year the family, who lived in New York, left for a new home in Arizona. As they passed through Oklahoma, another car struck their Audi in the rear. The crash caused a fire that severely burned Kay Robinson and her two children. The Robinsons brought a products-liability action (a suit claiming a product was defective) in a state court in Creek County, Oklahoma. They claimed the Audi's gas tank and fuel system were defectively designed and placed. They sued the manufacturer, Audi; the importer, Volkswagen of America; the regional distributor, World-Wide Volkswagen Corp.; and the dealer, Seaway. World-Wide and Seaway were incorporated in New York and did business there. World-Wide distributed cars to dealers in New York, New Jersey, and Connecticut. The Robinsons offered no evidence that either company did business in Oklahoma, shipped or sold products there, had an agent there to receive process, or advertised in media aimed at Oklahoma. There was no showing that any car either company sold had ever entered Oklahoma, except this one.

Issues

1. Does the Due Process Clause allow an Oklahoma court to exercise in personam jurisdiction over a New York car dealer and its regional distributor when their only connection with Oklahoma is that a car sold in New York to New York residents was in an accident there?
2. Can jurisdiction rest on the foreseeability that a car sold in New York might be driven to Oklahoma, or on revenue the sellers earn because cars can be used in distant States?

Holding

Oklahoma could not exercise jurisdiction over World-Wide and Seaway. They carried on no activity in Oklahoma, and nothing showed that they served its market. Their only link was one car that its buyers drove into the State. That unilateral act, the foreseeability of such travel, and any revenue tied to a car's mobility could not supply the minimum contacts that due process requires.