Case
World-Wide Volkswagen Corp. v. Woodson
Answer: World-Wide Volkswagen Corp. v. Woodson (1980). The Court held Oklahoma could not exercise specific personal jurisdiction over the New York retailer and regional distributor because they had no purposeful contacts with Oklahoma; foreseeability that a product might travel there was insufficient. The Court offered a contrasting stream-of-commerce example requiring purposeful efforts to serve the forum.
Rule to remember
World-Wide Volkswagen Corp. v. Woodson (1980) is the landmark personal-jurisdiction case holding that foreseeability alone is not enough; a defendant must purposefully avail itself of the forum for specific jurisdiction to comport with due process.
Key elements and checks
- Facts: NY purchasers crash in OK; they sue the out-of-state retail dealer and distributor where the car was bought.
- Rule: Specific jurisdiction requires purposeful availment plus a claim arising out of or relating to those contacts, and fairness.
- Foreseeability alone does not establish minimum contacts for due process.
- Stream-of-commerce example: jurisdiction can be proper when a manufacturer/distributor purposefully seeks to serve the forum market with expected sales there.
- Application: No offices, sales, services, or targeted advertising in the forum defeats specific jurisdiction for local sellers.
- Contrast: General jurisdiction depends on being “at home,” not satisfied here.
In the source’s words
““Yet ‘foreseeability’ alone has never been a sufficient benchmark for personal jurisdiction under the Due Process Clause.””
Minimum Contact Requirements for Personal Jurisdiction | U.S. Constitution Annotated (LII)
““that delivers its products into the stream of commerce with the expectation that they will be purchased . . . in the forum State””
Minimum Contact Requirements for Personal Jurisdiction | U.S. Constitution Annotated (LII)
States vary in how they interpret stream-of-commerce after Asahi and Nicastro, and long-arm statutes differ in breadth. Always check the forum’s statute and controlling precedent.