World-Wide Volkswagen Corp. v. Woodson
Encyclopedia
World-Wide Volkswagen Corp v. Woodson, is a United States Supreme Court case involving strict products liability, personal injury
and various procedural issues and considerations. The 1980 opinion, written by Justice Byron White, is included in the first-year civil procedure
curriculum
at nearly every American
law school
for its focus on personal jurisdiction.
100 LS automobile from Seaway Volkswagen, Inc. in Massena
, New York, in 1976. The following year, as Kay Robinson passed through Oklahoma
on Interstate 44
en route to the Robinsons' new home in Arizona
, the Audi was struck from the rear by a drunk driver in a 1971 Ford Torino
. The impact of the collision itself did not directly injure any of the Robinsons, but the crash resulted in the Audi's doors jamming shut and a puncture in the car's gas tank. A fire then severely burned the trapped Kay Robinson and her two children riding in the Audi, Eva and Sam.
or assets and was therefore judgment proof
. The Robinsons claimed that a product defect in the car
led to the injuries they sustained—specifically, the Audi's gas tank was located beneath the trunk
, in an area that the Robinsons claimed was susceptible to being punctured and igniting in a rear-end collision
. They brought suit against the automobile’s manufacturer (Audi), its importer (Volkswagen of America), its regional distributor
(World-Wide Volkswagen Corp.), and its retailer dealer
(Seaway Volkswagen).
The Robinsons' Oklahoma attorney brought the lawsuit in state court in Creek County, Oklahoma
, the county in which the accident had occurred. Creek County was at that time known as home to some of the most plaintiff sympathetic juries in the country. However, since the lawsuit met requirements for concurrent jurisdiction
in both state and federal court, Audi and Volkswagen
would have had the ability to ask for the case to be removed
from state court in Creek County and taken directly to federal court
. One of the factors which governs concurrent jurisdiction is diversity of citizenship
, or whether a defendant and plaintiff are from the same state. In the case of multiple defendants, if one defendants' state citizenship
matches the plaintiff's, concurrent federal jurisdiction does not apply and the case cannot be removed to federal court unless the case concerns a matter of federal law. It has therefore been stated that the reason the Robinsons' attorney added the New York regional distributor and New York dealership as defendants was to prevent Audi and Volkswagen from being able to remove the case from what was generally seen as a Creek County pro-plaintiffs' jury to what would be a federal court jury in Tulsa that might be more sympathetic to the car manufacturers' case. The Robinsons had not yet completed a move to Arizona, so they were still considered to be legal residents of New York.
The Robinsons first sued only Volkswagen of America
, World-Wide, and Seaway. They later amended the suit to include Volkswagenwerk Aktiengesellschaft (Volkswagen AG), the German parent company. A second amendment was included after they learned during formal discovery that Audi NSU Auto Union Aktiengesellschaft (Audi AG) was the manufacturing parent company rather than Volkswagen AG; they substituted Audi AG for Volkswagen AG.
When they were brought in as defendants in the case, World-Wide and Seaway claimed that Oklahoma’s exercise of personal or in personam jurisdiction over them would offend the limitations on states' jurisdiction imposed by the Due Process Clause of the Fourteenth Amendment
to the Constitution of the United States; they asked to be removed from the suit. Audi and Volkswagen, which sold cars in the state of Oklahoma, did not attempt to assert that the Oklahoma state court had no jurisdiction over them.
with Oklahoma, such that these defendants would be subject to the jurisdiction of the Oklahoma state courts.
The district court rejected World-Wide and Seaway's constitutional claim and reaffirmed that original ruling in denying petitioners’ motion for reconsideration.
The Due Process Clause of the 14th Amendment limits the power of a state court to exercise personal or in personam jurisdiction against a nonresident defendant. Due process requires that the defendant be given adequate notice of the suit. A state court may exercise personal jurisdiction over a nonresident only so long as there exist "minimum contacts
" between the defendant and the forum state.
The court stated that the concept of minimum contacts can be seen to perform two related but distinguishable functions. It protects the defendant against the burdens of litigating in a distant or inconvenient forum and it acts to ensure that the States, through their courts, do not reach out beyond the limits imposed on them by their status as coequal sovereigns in a federal system.
The 14th Amendment provides protection against inconvenient litigation, typically described in terms of “reasonableness” or “fairness”: “Does not offend ‘traditional notions of fair play and substantial justice.” The relationship between the defendant and forum must be “reasonable.” The burden on the defendant is to be balanced against other factors, including the plaintiff’s interest in obtaining convenient and effective relief.
The due process clause “does not contemplate that a state may make binding a judgment in personam against an individual or corporate defendant with which the state has no contacts, ties or relations.” Even if the defendant would suffer minimal or no inconvenience from being forced to litigate before the tribunals of another state, even if the forum state has a strong interest in applying its law to the controversy, and even if the forum state is the most convenient location for litigation, the Due Process Clause may sometimes act to divest the state of its power to render a valid judgment.
The petitioners' contentions were deemed correct by the Supreme Court, which agreed that the two corporations did not have minimum contacts in Oklahoma, did not avail themselves of any of the privileges or benefits of Oklahoma law; Oklahoma therefore had no jurisdiction over the two companies.
The Robinson's counterclaim and Justice [Brennan]'s dissenting opinion were based on foreseeability- a car sold in New York is mobile, and therefore it was foreseeable by World-Wide and Seaway that a car sold by them could subsequently lead to an injury in Oklahoma. The majority opinion of the Supreme Court rejected this argument, saying that foreseeability alone could not provide the basis for personal jurisdiction over a defendant and the two petitioning companies had no other contacts with Oklahoma.
, where a jury sided with the two car companies. The Tulsa jury indicated that they believed the speed of Lloyd Hull's car, rather than the Audi's gas tank, was responsible for the fire.
Personal injury
Personal injury is a legal term for an injury to the body, mind or emotions, as opposed to an injury to property. The term is most commonly used to refer to a type of tort lawsuit alleging that the plaintiff's injury has been caused by the negligence of another, but also arises in defamation...
and various procedural issues and considerations. The 1980 opinion, written by Justice Byron White, is included in the first-year civil procedure
Civil procedure
Civil procedure is the body of law that sets out the rules and standards that courts follow when adjudicating civil lawsuits...
curriculum
Curriculum
See also Syllabus.In formal education, a curriculum is the set of courses, and their content, offered at a school or university. As an idea, curriculum stems from the Latin word for race course, referring to the course of deeds and experiences through which children grow to become mature adults...
at nearly every American
United States
The United States of America is a federal constitutional republic comprising fifty states and a federal district...
law school
Law school
A law school is an institution specializing in legal education.- Law degrees :- Canada :...
for its focus on personal jurisdiction.
Accident
Harry and Kay Robinson purchased a new AudiAudi
Audi AG is a German automobile manufacturer, from supermini to crossover SUVs in various body styles and price ranges that are marketed under the Audi brand , positioned as the premium brand within the Volkswagen Group....
100 LS automobile from Seaway Volkswagen, Inc. in Massena
Massena (town), New York
Massena is a town in St. Lawrence County, New York, United States. The town is on the northern border of the county and is nicknamed "The Gateway to the Fourth Coast". The population was 13,121 at the 2000 census. The town of Massena contains a village also called Massena...
, New York, in 1976. The following year, as Kay Robinson passed through Oklahoma
Oklahoma
Oklahoma is a state located in the South Central region of the United States of America. With an estimated 3,751,351 residents as of the 2010 census and a land area of 68,667 square miles , Oklahoma is the 28th most populous and 20th-largest state...
on Interstate 44
Interstate 44
Interstate 44 is a major highway in the central United States. Its western terminus is in Wichita Falls, Texas at a concurrency with US 277, US 281 and US 287; its eastern terminus is at the Illinois state line on the Poplar Street Bridge over the Mississippi River in St...
en route to the Robinsons' new home in Arizona
Arizona
Arizona ; is a state located in the southwestern region of the United States. It is also part of the western United States and the mountain west. The capital and largest city is Phoenix...
, the Audi was struck from the rear by a drunk driver in a 1971 Ford Torino
Ford Torino
The Ford Torino is an intermediate automobile produced by the Ford Motor Company for the North American market between 1968 and 1976. The car was named after the city of Turin , which is considered the Detroit of Italy...
. The impact of the collision itself did not directly injure any of the Robinsons, but the crash resulted in the Audi's doors jamming shut and a puncture in the car's gas tank. A fire then severely burned the trapped Kay Robinson and her two children riding in the Audi, Eva and Sam.
Lawsuit
The Robinsons did not bring a suit against Lloyd Hull, the drunk driver. He had no insuranceInsurance
In law and economics, insurance is a form of risk management primarily used to hedge against the risk of a contingent, uncertain loss. Insurance is defined as the equitable transfer of the risk of a loss, from one entity to another, in exchange for payment. An insurer is a company selling the...
or assets and was therefore judgment proof
Judgment proof
The term judgment proof is most commonly used in tort law contexts to refer to defendants or potential defendants who are financially insolvent...
. The Robinsons claimed that a product defect in the car
Čar
Čar is a village in the municipality of Bujanovac, Serbia. According to the 2002 census, the town has a population of 296 people.-References:...
led to the injuries they sustained—specifically, the Audi's gas tank was located beneath the trunk
Trunk
Trunk may refer to:In biology:*Trunk, an elephant's proboscis or nose*Trunk, torso*Trunk , a tree's central superstructureIn containers:*Trunk , a large storage compartment*Trunk...
, in an area that the Robinsons claimed was susceptible to being punctured and igniting in a rear-end collision
Rear-end collision
A rear-end collision is a traffic accident wherein a vehicle crashes into the vehicle in front of it, usually caused by tailgating or panic stops...
. They brought suit against the automobile’s manufacturer (Audi), its importer (Volkswagen of America), its regional distributor
Distributor
A distributor is a device in the ignition system of an internal combustion engine that routes high voltage from the ignition coil to the spark plugs in the correct firing order. The first reliable battery operated ignition was developed by Dayton Engineering Laboratories Co. and introduced in the...
(World-Wide Volkswagen Corp.), and its retailer dealer
Dealer
Dealer may refer to:* Antique dealer, someone who sells Antiques* Art dealer, gallerist, somebody or company that buys and sells art...
(Seaway Volkswagen).
The Robinsons' Oklahoma attorney brought the lawsuit in state court in Creek County, Oklahoma
Creek County, Oklahoma
Creek County is a county located in the U.S. state of Oklahoma. As of 2010, the population was 69,967. Its county seat is Sapulpa.-Geography:According to the U.S. Census Bureau, the county has a total area of , of which is land and is water....
, the county in which the accident had occurred. Creek County was at that time known as home to some of the most plaintiff sympathetic juries in the country. However, since the lawsuit met requirements for concurrent jurisdiction
Concurrent jurisdiction
Concurrent jurisdiction exists where two or more courts from different systems simultaneously have jurisdiction over a specific case. This situation leads to forum shopping, as parties will try to have their civil or criminal case heard in the court that they perceive will be most favorable to...
in both state and federal court, Audi and Volkswagen
Volkswagen
Volkswagen is a German automobile manufacturer and is the original and biggest-selling marque of the Volkswagen Group, which now also owns the Audi, Bentley, Bugatti, Lamborghini, SEAT, and Škoda marques and the truck manufacturer Scania.Volkswagen means "people's car" in German, where it is...
would have had the ability to ask for the case to be removed
Removal jurisdiction
In the United States, removal jurisdiction refers to the right of a defendant to move a lawsuit filed in state court to the federal district court for the federal judicial district in which the state court sits. This is a general exception to the usual American rule giving the plaintiff the right...
from state court in Creek County and taken directly to federal court
United States district court
The United States district courts are the general trial courts of the United States federal court system. Both civil and criminal cases are filed in the district court, which is a court of law, equity, and admiralty. There is a United States bankruptcy court associated with each United States...
. One of the factors which governs concurrent jurisdiction is diversity of citizenship
Diversity jurisdiction
In the law of the United States, diversity jurisdiction is a form of subject-matter jurisdiction in civil procedure in which a United States district court has the power to hear a civil case where the persons that are parties are "diverse" in citizenship, which generally indicates that they are...
, or whether a defendant and plaintiff are from the same state. In the case of multiple defendants, if one defendants' state citizenship
Citizenship
Citizenship is the state of being a citizen of a particular social, political, national, or human resource community. Citizenship status, under social contract theory, carries with it both rights and responsibilities...
matches the plaintiff's, concurrent federal jurisdiction does not apply and the case cannot be removed to federal court unless the case concerns a matter of federal law. It has therefore been stated that the reason the Robinsons' attorney added the New York regional distributor and New York dealership as defendants was to prevent Audi and Volkswagen from being able to remove the case from what was generally seen as a Creek County pro-plaintiffs' jury to what would be a federal court jury in Tulsa that might be more sympathetic to the car manufacturers' case. The Robinsons had not yet completed a move to Arizona, so they were still considered to be legal residents of New York.
The Robinsons first sued only Volkswagen of America
Volkswagen of America
Volkswagen Group of America, Inc. , is the North American operational headquarters, and subsidiary of the Volkswagen Group of automobile companies of Germany. VWoA is responsible for five marques: Audi, Bentley, Bugatti, Lamborghini, and Volkswagen cars. It also controls VW Credit, Inc...
, World-Wide, and Seaway. They later amended the suit to include Volkswagenwerk Aktiengesellschaft (Volkswagen AG), the German parent company. A second amendment was included after they learned during formal discovery that Audi NSU Auto Union Aktiengesellschaft (Audi AG) was the manufacturing parent company rather than Volkswagen AG; they substituted Audi AG for Volkswagen AG.
When they were brought in as defendants in the case, World-Wide and Seaway claimed that Oklahoma’s exercise of personal or in personam jurisdiction over them would offend the limitations on states' jurisdiction imposed by the Due Process Clause of the Fourteenth Amendment
Fourteenth Amendment to the United States Constitution
The Fourteenth Amendment to the United States Constitution was adopted on July 9, 1868, as one of the Reconstruction Amendments.Its Citizenship Clause provides a broad definition of citizenship that overruled the Dred Scott v...
to the Constitution of the United States; they asked to be removed from the suit. Audi and Volkswagen, which sold cars in the state of Oklahoma, did not attempt to assert that the Oklahoma state court had no jurisdiction over them.
Issue
Whether Seaway Volkswagen and Worldwide Volkswagen had sufficient minimum contactsMinimum contacts
Minimum contacts is a term used in the United States law of civil procedure to determine when it is appropriate for a court in one state to assert personal jurisdiction over a defendant from another state...
with Oklahoma, such that these defendants would be subject to the jurisdiction of the Oklahoma state courts.
Lower courts' decisions
The respondents were fully independent corporations whose relationship with each other and Volkswagen and Audi were contractual only. The petitioners (Robinsons) adduced no evidence that either respondent (World-Wide or Seaway) did any business in Oklahoma, shipped or sold any product to or in that state, had an agent to receive process there, or purchased advertisements in any media calculated to reach Oklahoma. The Robinson's counsel conceded at oral argument that there was no showing that any automobile sold by either World-Wide or Seaway had ever entered Oklahoma with the single exception of the vehicle involved in this case.The district court rejected World-Wide and Seaway's constitutional claim and reaffirmed that original ruling in denying petitioners’ motion for reconsideration.
Supreme Court decision
The United States Supreme Court reversed the decision of the federal appeals court and agreed with World-Wide and Seaway that Oklahoma did not have jurisdiction over them.The Due Process Clause of the 14th Amendment limits the power of a state court to exercise personal or in personam jurisdiction against a nonresident defendant. Due process requires that the defendant be given adequate notice of the suit. A state court may exercise personal jurisdiction over a nonresident only so long as there exist "minimum contacts
Minimum contacts
Minimum contacts is a term used in the United States law of civil procedure to determine when it is appropriate for a court in one state to assert personal jurisdiction over a defendant from another state...
" between the defendant and the forum state.
The court stated that the concept of minimum contacts can be seen to perform two related but distinguishable functions. It protects the defendant against the burdens of litigating in a distant or inconvenient forum and it acts to ensure that the States, through their courts, do not reach out beyond the limits imposed on them by their status as coequal sovereigns in a federal system.
The 14th Amendment provides protection against inconvenient litigation, typically described in terms of “reasonableness” or “fairness”: “Does not offend ‘traditional notions of fair play and substantial justice.” The relationship between the defendant and forum must be “reasonable.” The burden on the defendant is to be balanced against other factors, including the plaintiff’s interest in obtaining convenient and effective relief.
The due process clause “does not contemplate that a state may make binding a judgment in personam against an individual or corporate defendant with which the state has no contacts, ties or relations.” Even if the defendant would suffer minimal or no inconvenience from being forced to litigate before the tribunals of another state, even if the forum state has a strong interest in applying its law to the controversy, and even if the forum state is the most convenient location for litigation, the Due Process Clause may sometimes act to divest the state of its power to render a valid judgment.
The petitioners' contentions were deemed correct by the Supreme Court, which agreed that the two corporations did not have minimum contacts in Oklahoma, did not avail themselves of any of the privileges or benefits of Oklahoma law; Oklahoma therefore had no jurisdiction over the two companies.
The Robinson's counterclaim and Justice [Brennan]'s dissenting opinion were based on foreseeability- a car sold in New York is mobile, and therefore it was foreseeable by World-Wide and Seaway that a car sold by them could subsequently lead to an injury in Oklahoma. The majority opinion of the Supreme Court rejected this argument, saying that foreseeability alone could not provide the basis for personal jurisdiction over a defendant and the two petitioning companies had no other contacts with Oklahoma.
Subsequent litigation
With World-Wide and Seaway unable to be held as defendants in the Robinsons' case against Audi and Volkswagen, the case now had diversity of citizenship and was concurrently eligible for both state and federal court. Audi and Volkswagen asked for the case to be removed from Creek County into federal district court in Tulsa, OklahomaTulsa, Oklahoma
Tulsa is the second-largest city in the state of Oklahoma and 46th-largest city in the United States. With a population of 391,906 as of the 2010 census, it is the principal municipality of the Tulsa Metropolitan Area, a region with 937,478 residents in the MSA and 988,454 in the CSA. Tulsa's...
, where a jury sided with the two car companies. The Tulsa jury indicated that they believed the speed of Lloyd Hull's car, rather than the Audi's gas tank, was responsible for the fire.
See also
External links
- Case Brief for World-Wide Volkswagen Corp. v. Woodson at Lawnix.com
- [ Supreme Court of the United States]