## Facts

- Harry and Kay Robinson, then New York residents, bought a new Audi from Seaway Volkswagen, a New York retailer.
- World-Wide Volkswagen, a New York corporation, distributed Audi/Volkswagen vehicles to dealers in New York, New Jersey, and Connecticut.
- While the Robinsons were relocating and driving through Oklahoma, their Audi was rear-ended, the fuel tank punctured, and a fire severely burned Kay Robinson and two children.
- The Robinsons sued in Oklahoma state court on a products-liability theory, naming the manufacturer, the U.S. importer, World-Wide Volkswagen (distributor), and Seaway (dealer).
- World-Wide Volkswagen and Seaway had no business operations in Oklahoma: no sales, services, solicitation, or advertising directed to Oklahoma, and no use of Oklahoma legal benefits.
- Their sole connection to Oklahoma was that the Robinsons drove the car there and the accident occurred there.

## Issues

1. Whether the Due Process Clause permits an Oklahoma court to exercise personal jurisdiction over a nonresident dealer and regional distributor that conducted no activities in Oklahoma when the only forum link is the plaintiff’s use of the product in Oklahoma.

## Decision

- The Supreme Court reversed the Oklahoma Supreme Court.
- Oklahoma could not, consistent with due process, exercise in personam jurisdiction over World-Wide Volkswagen and Seaway.
- The defendants lacked the minimum contacts with Oklahoma required before a state court may assert personal jurisdiction.

## Legal Principles

- A state may exercise personal jurisdiction over a nonresident defendant only if the defendant has “minimum contacts” with the forum such that litigation there does not offend “traditional notions of fair play and substantial justice.”
- The relevant foreseeability is not that a product might travel to the forum, but that the defendant’s forum-directed conduct makes it reasonable to anticipate being haled into court there.
- The plaintiff’s unilateral activity (including transporting the product into the forum) cannot supply the defendant’s required contacts with the forum.
- Fairness factors (burden on the defendant, forum interests, plaintiff convenience, and interstate efficiency) are assessed only after minimum contacts exist; they cannot cure an absence of forum-directed contacts.
- Jurisdiction may be proper when a defendant places goods into the stream of commerce with the expectation they will be purchased in the forum state, but not where the defendant’s distribution and sales are confined to other states without forum targeting.

## Conclusion

Because the New York dealer and regional distributor did not purposefully direct conduct toward Oklahoma and had no contacts there beyond the consumers’ decision to drive the car into the state, Oklahoma’s exercise of personal jurisdiction violated the Due Process Clause.


World-Wide Volkswagen Corp. v. Woodson, 444 U.S. 286 (1980)