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Heading: World-Wide Volkswagen Corp. v. Woodson, 444 U.S. 286 (1980) p 65.

Facts: Plaintiffs bought a new car from a New York dealer and then decided to move to Arizona. They were driving their car to Arizona when they were rear ended in Oklahoma. As a result of the collision a fire erupted severely injuring the wife and two children. The retailer was a New York corporation with operations entirely in New York.

Procedure: Oklahoma trial court held it had jurisdiction under an Oklahoma statute that supported suit if a defendant caused "tortuous injury in this state." Oklahoma SC upheld the trial court. The US Supreme Court reversed.

Issue: Did Oklahoma have jurisdiction over the retailer and distributor?

Rule: As with all the previous cases, there must be a requirement of "minimum contact" before there is jurisdiction. Minimum contact is not satisfied when D had absolutely no dealings with Oklahoma other than the fact that the car sold by it was eventually driven to Oklahoma.

Holding: Oklahoma did not have jurisdiction. Find a total absence of those affiliating circumstances that are a necessary predicate to any exercise of state court jurisdiction.

Rationale: In order to exercise jurisdiction there must be minimum contacts. This protects D from burdens of litigating in a distant or inconvenient forum and it acts to ensure that states do not reach out beyond the limits imposed upon them by the Constitution. The relationship between D and P must be such that it is reasonable to require corporation to defend the particular suit which is brought there. Here, these requirements were absent. They close no sales and perform no service in Oklahoma. Although it might be foreseeable that an automobile might cause injury in Oklahoma, foreseeability alone has never been a sufficient benchmark for personal jurisdiction.

Policy/Notes: Brennan dissent: The decision accords too little weight to the strength of the forum state’s interest in the case and fail to explore whether there would be any actual inconvenience to the defendant. Sufficient contacts are found to be here to defend this action in Oklahoma.

Writ of prohibition:

Only final judgement can be appealed. If you want a review of the decision you must ask for a writ of prohibition. This judgement was interlocutory judgement. Was only a judgement during the trial process. Every motion, objection, etc. requires an interlocutory judgement.

Oklahoma was locus and forum. Said manufacturer, distributor, retailer should be taken to court in Oklahoma. World-wide-Volkswagen and Seaway appealed to US Supreme Court.