We are continuing to look at specific jurisdiction. The case outlined below shows the principles necessary for a court to find in personum specific jurisdiction. Before getting into the case, here are some of the factors the court considers when deciding if a state has jurisdiction.
- The interests of the forum state with proceeding in litigation
- Plaintiff’s interest in obtaining convenient relief
- The interstate judicial system’s interest in obtaining efficient resolutions
- Finally, the interest of several states to further “substantive social policies”
Are any of these factors of reasonableness sufficient for a court to find personal jurisdiction? No.
World-Wide Volkswagen v. Woodson
444 U.S. 286 (1980).
Volkswagen is the defendant and Woodson is the plaintiff. Volkswagen sought dismissal for lack of specific personal jurisdiction. Lost in the state district and supreme courts. Appealed to SCOTUS.
Question
“Whether an Oklahoma court can exercise in personam jurisdiction over a non-resident defendant when the defendants only connection with the forum state is that a product sold in New York to New York residents who later became involved in an accident in Oklahoma.”
Rule
The defendant’s contact with the state is necessary. Factors of reasonableness are necessary. However, one or the other is not enough to find personal jurisdiction.
Holding
The defendant had no contacts or ties with the forum state and is thus protected from suit in the Oklahoma. Judgement reversed.
Facts
Defendants are based in New York, Connecticut, and New Jersey. Plaintiffs purchased an automobile from Defendants in New York and later moved to Arizona. As they were moving, they were in an accident in Oklahoma, which caused an automobile fire and burned the plaintiffs. They filed suit in Oklahoma and the defendants moved for the action to be dismissed because of lack of personal jurisdiction.
Consider the states at play
- Defendants are based in New York, Connecticut, and New Jersey
- Plaintiffs are domiciled in New York, but changing to Arizona
- Claim occurred in Oklahoma.
- Defendants run no advertisements, dealerships, or the like in Arizona.
- The only known vehicle from this dealership to run through the area is the one in question.
Trial court said that the defendants should have “foreseen” that their products, being mobile in nature, would have the possibility of making it to Oklahoma. Therefore, there is jurisdiction. The OK Supreme Court agreed.
Analysis
The court begins by examining the rules outlined through common law. They look at Ponnoyer, International Shoe, and Hanson. From these cases they determine that there are several factors that can be used to look at the contacts and reasonableness of a court to exercise in personam jurisdiction. Additionally, they say that foreseeability alone (meaning, the defendant should have known that its products could have traveled to Oklahoma) is not enough to establish jurisdiction.
Although it would have been reasonable to exercise personal jurisdiction, SCOTUS determined that there was not a sufficient contact with the forum state. Therefore, there could be no specific jurisdiction and the case is dismissed.
The dissent disagrees. They say that the majority fails to consider effectively the interest of the forum state in litigating this case and the burden of the defendants. Taking these two factors into consideration, the court should have been able to find that the forum state had an interest in this case because the accident occurred in the state, etc. Additionally, because the product is mobile by nature, the defendants purposefully had intended it to go to other states. Because there is the interconnected highway system, and technology has advanced, the burden on the defendant is minimal.
Takeaways
Here, to find personal jurisdiction, a person must have a contact with the forum state and litigation must be considered reasonable. Reasonableness can be determined by 5 factors shown below. If a contact or reasonableness is not met, then there is no jurisdiction.
- The interests of the forum state with proceeding in litigation
- Plaintiff’s interest in obtaining convenient relief
- The interstate judicial system’s interest in obtaining efficient resolutions
- Finally, the interest of several states to further “substantive social policies”
I find it interesting to note that the contact relates to the defendant while the reasonableness factors relate to the plaintiff and forum state.
Additional Notes
The plaintiffs in this case would have known this is a difficult case. So, they would have wanted a jury that was more partial to their case. Therefore, they filed in a state court so that the jury pool was smaller. Here, the defendants want the federal court (because they are better for corporations) and the plaintiffs want the state courts.
Because the plaintiffs were on their way to Arizona, their domicile still had not changed from New York. They sue four parties
- Audi (Germany)
- Volkswagen of America (New Jersey)
- Worldwide Volkswagen (New York)
- Seaway (New York)
Because Worldwide Volkswagen and and Seaway are in New York, and plaintiffs are still New York domicile, this case can’t be resolved by a federal court.
So, we need to see if Worldwide Volkswagen and Seaway are subject to personal jurisdiction in New York. Seaway is the dealership and Worldwide Volkswagen sent the manufactured product to the dealership.
Here, the case was dismissed and then went to the federal courts where Audi won.
Analysis
The court examines the subject of “foreseeability”. Here, the court says that there is foreseeability but alone, it is not enough to determine specific personal jurisdiction. They need to evaluate the other factors such as did the the defendants purposefully avail themselves to the state. Here they did not, because they didn’t sell, advertise, or service there.
The unilateral conduct of the plaintiff does not establish minimum contacts. Here, the plaintiffs took the car out of New York, not the defendants. Even if the plaintiff tells the person that they were taking the product out of state, it is still only foreseeability, there is nothing that the defendant is using to purposefully avail to the forum state. The defendant must do something where they could have reasonably anticipate being haled into court there.
Big Takeaways
- The parties matter. Ask ourselves why a party may sue in a certain court and why the defendants want to be in a certain jurisdiction.
- Foreseeability isn’t enough (it is a factor), but the conduct of the defendants determine whether the contacts are sufficient.
- Even if a person is lost and causes an accident in that state, they could have foreseen being lost and their conduct resulted in the claim.
Here’s the rule:
- The conduct of the defendant personally avails themselves through their contact.
- Whether it’s reasonable for the court to hear the case.
Disclaimer
The content contained in this article may contain inaccuracies and is not intended to reflect the opinions, views, beliefs, or practices of any academic professor or publication. Instead, this content is a reflection on the author’s understanding of the law and legal practices.
