Venue: | SCOTUS |
Facts: | Two folks buy an Audi from Seaway VW in NY. Then they drive towards AZ, their new home. In OK, there's a smash-up, and wife and kids are burned. Neither World-Wide nor Seaway does any business in OK, nor has an agent there, nor advertises there. In fact, this is maybe the only one of their cars ever to travel to OK, as far as we know. |
Posture: | Suit in OK state court. Manufacturer, importer, distributor, and dealer are joined. Dealer (Seaway) and distributor (World-Wide) mane special appearances objecting to personal jurisdiction as a matter of due process. OK SC refuses to issue a "writ of prohibition" restraining the trial court from exercising personal jurisdiction. Appeal. |
Issue: | Can an OK state court exercise in personam jurisdiction in a products liability suit over a nonresident retailer and distributor when their only connection to OK is that they sold an automobile that got into an accident there? |
Holding: | No. Reversed. |
Rule: | Personal jurisdiction requires "minimum contacts," not just foreseeability. |
Reasoning: | If Foreseeability were the standard, every retailer would be liable
everywhere. We need to protect defendants against unreasonable
burdens by ensuring that states don't over-reach the limits
placed upon them as co-equal sovereigns.
There's just no sign of minimum contacts here. No "purposeful availment." This is just a unilateral assertion. It's too attenuated. |
Dicta: | Brennan, dissenting: OK has a strong interest here. People who sell autos can't reasonably plead ignorance of their mobility. |