World-Wide Volkswagen v. Woodson
Citation: 444 U.S. 286 (1980)
Facts
The Robinsons purchased an Audi in New York and were involved in a car accident in Oklahoma. They sued the regional distributor (World-Wide Volkswagen) and the retailer (Seaway) in Oklahoma. Neither defendant had any contacts with Oklahoma — they sold cars only in the New York/New Jersey/Connecticut tri-state area.
Issue
Does the foreseeability that a car could travel to another state and cause injury there establish minimum contacts with that state?
Holding
No. The mere foreseeability that a product might end up in a forum state is insufficient for personal jurisdiction. The defendant must have purposefully availed itself of the forum state’s laws and privileges.
Rule
Purposeful availment: A defendant must purposefully direct its activities at the forum state. The relevant foreseeability is whether the defendant could reasonably anticipate being haled into court in the forum, not merely whether its product might foreseeably end up there. Unilateral acts of third parties cannot create jurisdiction.
Significance
- Establishes purposeful availment as the core of minimum contacts analysis
- Rejects “mere foreseeability” of product travel as a basis for jurisdiction
- Introduces the “stream of commerce” question: when a manufacturer places a product into the stream of commerce, does that alone establish purposeful availment in states where the product ends up? This question was later split in Asahi Metal Industry v. Superior Court (plurality: must be “plus” beyond stream of commerce placement)
- Also articulates the interstate federalism dimension: states cannot reach beyond their borders; limiting jurisdiction protects the federal structure