Robinsons purchased an Audi from D (Seaway Volks) in NY.
Following year, Robinsons moved to AZ, passing through OK where they were in an accident. Car caught on fire.
Robinsons sued auto manufacturer, importer, regional distributor, and retail dealer in OK.
Regional distributor (World-wide Volks) and retail dealer (Seaway Volks) are the parties in this case about jurisdiction.
Procedural History:
D lost in District Court.
D lost appeal in Supreme Court of OK.
D won appeal in SCOTUS, OK has no jurisdiction.
Issues:
Can a forum state exercise in personam jurisdiction over a party when that party's only connection with that forum state is that some of the products distributed/sold by that party were involved in a tortuous act in that state?
Holding/Rule:
A forum state can exercise in personam jurisdiction over a party whose conduct and connection with the forum state are such that he should reasonably anticipate being haled into court there.
Jurisdiction may be exercised if a party delivers its products into the "stream of commerce" with the expectation that they will be purchased by consumers in the forum state.
The mere "unilateral activity" of a party who claims some relationship with the nonresident defendant is not enough to satisfy the requirement of minimum contact in a forum state.
Reasoning:
Ds had no sales and performed no services in OK. They avail themselves to none of the privileges and benefits of OK law. Thus, there was no way to establish the D had minimum contacts with OK.
The foreseeability that is critical to due process analysis is not the mere likelihood that a product will find its way into a forum state. It is that the Ds conduct and connection with the forum state are such that he should reasonably anticipate being haled into court there.
If foreseeability were the only criteria, "Every seller of chattels would in effect appoint the chattel his agent for service of process."
Even if the D would suffer minimal or no inconvenience from being forced to litigate in a particular state and even if the forum state is the "best" place for litigation, DP can still deprive that state of taking jurisdiction over a case.
Dissent:
Marshall…
Jurisdiction should be valid in this case because the purposeful and deliberate actions of the Ds in choosing to become part of a nationwide network for marketing and servicing cars.
Jurisdiction should be valid if a product enters a state in the course of its intended use by the consumer.
Brennan…
If the burden to the D is not unreasonable and if the forum state has an interest in allowing the litigation, it should be permitted to do so.
Minimum contacts must exist "among the parties, the contested transaction, and the forum state".
Because of changes in transportation since Shoe, the constitutional concepts of fairness no longer require the extreme concern for Ds as was once necessary.
Notes:
The dealership and distributor receive no benefit if vehicles are driven into OK.
The P wanted the case to stay in state court, so that's the main reason the distributor and dealership were added to the complaint.
The appellee in this case is a judge because the Ps did a writ of prohibition against the judge that ruled against them in jurisdictional issues.
The court only had a problem with the "minimum contacts" test, not with the "fair play and substantial justice" test
