World-Wide Volkswagen Corp. v. Woodson

In World-Wide Volkswagen Corp. v. Woodson (1980) 444 U.S. 286, the plaintiffs, who were New York residents, purchased a vehicle from a New York retailer. (Id. at p. 288.) After they were injured in an accident in Oklahoma, the plaintiffs filed an action in that state against the manufacturer, the importer, the regional distributor, and the retail dealer, alleging that the accident was caused by the vehicle's defective design. (Ibid.) The regional distributor's market was limited to dealers in New York, New Jersey, and Connecticut, and the retailer dealer's sales were made in New York. (Ibid.) These corporations did not do business in Oklahoma, ship or sell products to that state, have an agent to receive process there, or advertise in Oklahoma. (Id. at p. 289.) The United States Supreme Court held that the Oklahoma court did not have personal jurisdiction over either the regional distributor or the retail dealer, because they had " 'no contacts, ties, or relations' " with that state. (Id. at p. 299.) In dicta, World-Wide Volkswagen discussed the purposeful availment element of the stream of commerce theory in connection with the international manufacturer and the importer of the vehicle, neither of which challenged personal jurisdiction. (World-Wide Volkswagen, supra, 444 U.S. at p. 288, fn. 3.) The court stated that "the foreseeability that is critical to due process analysis is not the mere likelihood that a product will find its way into the forum State. Rather, it is that the defendant's conduct and connection with the forum State are such that he should reasonably anticipate being haled into court there." (Id. at p. 297.) The court also observed: "When a corporation 'purposefully avails itself of the privilege of conducting activities with the forum State,' , it has clear notice that it is subject to suit there, and can act to alleviate the risk of burdensome litigation by procuring insurance, passing the expected costs on to customers, or, if the risks are too great, severing its connection with the State. Hence if the sale of a product of a manufacturer or distributor . . . is not simply an isolated occurrence, but arises from the efforts of the manufacturer or distributor to serve, directly or indirectly, the market for its product in other States, it is not unreasonable to subject it to suit in one of those States if its allegedly defective merchandise has there been the source of injury to its owner or to others. The forum State does not exceed its powers under the Due Process Clause if it asserts personal jurisdiction over a corporation that delivers its products into the stream of commerce with the expectation that they will be purchased by consumers in the forum State. " (Id. at pp. 297-298.)