World-Wide Volkswagen Corp. v. Woodson
1978 OK 131, 585 P.2d 351, 1978 Okla. LEXIS 504 (1978)
Premium Feature
Subscribe to Lexplug to listen to the Case Podcast.
Rule of Law:
Under Oklahoma's long-arm statute, a court may exercise personal jurisdiction over a non-resident defendant who causes a tortious injury within the state by an act committed outside the state, if that defendant derives substantial revenue from goods used or consumed within the state. Substantial revenue may be inferred from the mobile nature of a high-value product, making its use in the forum state foreseeable.
Facts:
- In 1977, Kay Eloise Robinson and her family purchased a new Audi automobile from Seaway Volkswagen, Inc. in New York.
- Seaway Volkswagen, Inc. was a retail dealership incorporated and doing business only in New York.
- World-Wide Volkswagen Corporation was the regional distributor for Audi automobiles in New York, New Jersey, and Connecticut.
- The Robinsons, residents of New York at the time of purchase, were later driving through Oklahoma while moving to a new home.
- While in Oklahoma, the Audi was struck from the rear by another vehicle.
- The collision caused the Audi's gasoline tank to rupture, resulting in a fire that severely injured Kay Robinson and her two children.
- Neither Seaway Volkswagen nor World-Wide Volkswagen conducted any business, solicited sales, had agents, or advertised in Oklahoma.
Procedural Posture:
- Kay Robinson and her family filed a products liability lawsuit in the District Court of Creek County, Oklahoma (a state trial court) against multiple defendants, including World-Wide Volkswagen and Seaway Volkswagen.
- Defendants World-Wide Volkswagen and Seaway Volkswagen made a special appearance in the District Court, challenging the court's exercise of personal jurisdiction over them.
- The respondent trial judge, Honorable Charles S. Woodson, denied the defendants' jurisdictional challenge.
- World-Wide Volkswagen and Seaway Volkswagen (petitioners) then brought an original action before the Supreme Court of Oklahoma, requesting a writ of prohibition to prevent the trial judge from exercising jurisdiction over them.
Premium Content
Subscribe to Lexplug to view the complete brief
You're viewing a preview with Rule of Law, Facts, and Procedural Posture
Issue:
Does an Oklahoma court have personal jurisdiction over a non-resident automobile retailer and a regional distributor whose only connection to Oklahoma is that a car they sold in New York was subsequently involved in an accident in Oklahoma?
Opinions:
Majority - Barnes, Justice
Yes. An Oklahoma court can exercise personal jurisdiction over the non-resident retailer and distributor because their conduct satisfies the state's long-arm statute. The court first rejected jurisdiction under the statutory provision for 'causing tortious injury in this state by an act or omission in this state,' distinguishing Oklahoma's specific statute from broader ones like Illinois's. It reasoned that applying this provision would render another section of the statute—addressing injuries in-state from acts out-of-state—superfluous. However, the court found jurisdiction was proper under the provision covering 'causing tortious injury in this state by an act or omission outside this state if he...derives substantial revenue from goods used or consumed...in this state.' The court held that because an automobile is inherently mobile, it was foreseeable to the petitioners that a car they sold could be used in Oklahoma. Based on the car's high retail value, the court inferred that the petitioners derived 'substantial revenue' from vehicles used in Oklahoma, thus satisfying the statutory requirements for personal jurisdiction.
Analysis:
This decision by the Oklahoma Supreme Court represents a highly expansive interpretation of personal jurisdiction, grounding its finding in the foreseeability of a product's mobility. By inferring 'substantial revenue' from the mere use of a high-value product within the state, the court significantly lowered the bar for hailing non-resident defendants into an Oklahoma court. This ruling set a precedent that a defendant's connection to a state could be established not by its own purposeful actions directed at the state, but by the unilateral activity of a consumer. The case's ultimate appeal to the U.S. Supreme Court would lead to a landmark decision clarifying and narrowing the 'minimum contacts' standard, making this state-level opinion a critical example of the jurisdictional boundaries that the Supreme Court later reined in.
Unlock the full brief for World-Wide Volkswagen Corp. v. Woodson