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Conflict of Laws Keyed to Brilmayer
World-Wide Volkswagen Corp. v. Woodson
Citation:
444 U.S. 286 (1980)
ProfessorBrittany L. Raposa
CaseCast™ – "What you need to know"
Facts
Plaintiffs, Harry and Kay Robinson, purchased a new Audi from Seaway Volkswagen, Inc., in Massena, New York. The following year, the Robinsons drove from New York to their new home in Arizona. While they were driving through Oklahoma, another car struck their Audi in the rear, which caused a fire. Kay and her two children were severely burned. The Robinson’s brought a product liability action in the District Court for Creek County, Oklahoma, claiming that their injuries resulted from defective design and placement of Audi’s gas tank and fuel system. Defendants were the Audi retailer, Seaway Volkswagen, Inc. (“Seaway”); it’s manufacturer, Audi NSU Auto Union Aktiengesellschaft (“Audi”); it’s importer, Volkswagen of America, Inc. (“Volkswagen”); and it’s regional distributor, World-Wide Volkswagen Corporation (“World-Wide”). World-Wide is incorporated and has its business office in New York. It distributes vehicles and parts and accessories to retail dealers in New York, New Jersey, and Connecticut. Seaway is incorporated and has its place of business in New York. Seaway and World-Wide are fully independent corporations whose relations with Volkswagen and Audi are contractual only. There was no evidence that World-Wide or Seaway did business in Oklahoma.
World-Wide and Seaway entered special appearances, claiming that Oklahoma’s exercise of jurisdiction over them would violate the Due Process Clause. The District Court rejected World-Wide and Seaway’s constitutional claim and reaffirmed the ruling denying World-Wide and Seaway’s petition for reconsideration. World-Wide and Seaway sought a writ of prohibition in the Supreme Court of Oklahoma to restrain the district judge from exercising in personam jurisdiction over them. The Supreme Court of Oklahoma held that personal jurisdiction over World-Wide and Seaway was authorized by Oklahoma’s Long-Arm Statute. The U.S. Supreme Court granted World-Wide and Seaway’s petition for certiorari.
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