Can a state court exercise personal jurisdiction over out-of-state defendants in a products liability case when the defendants' sole connection to the forum state is that their product, sold elsewhere, was involved in an accident within the state?

The Robinsons purchased a new Audi from Seaway Volkswagen in Massena, New York in 1976. The following year, while driving in Oklahoma, their vehicle was rear-ended, resulting in a fire that caused severe burns to Kay Robinson and her two children. The Robinsons subsequently filed a products-liability lawsuit in Oklahoma against multiple defendants: Audi (the manufacturer), Volkswagen of America (the importer), World-Wide Volkswagen Corp. (the regional distributor), and Seaway (the retail dealer).

World-Wide Volkswagen and Seaway are New York corporations with their business offices in that state. Neither company conducts business in Oklahoma, maintains agents there, or advertises within the state. The sole connection between these defendants and Oklahoma is the Audi automobile involved in the accident.

The Robinsons initiated a products-liability action against World-Wide Volkswagen Corp. and Seaway Volkswagen in the District Court for Creek County, Oklahoma. The defendants entered special appearances, challenging Oklahoma's jurisdiction over them on constitutional grounds. The District Court rejected their jurisdictional challenge.

Subsequently, the defendants sought a writ of prohibition from the Oklahoma Supreme Court to prevent the District Judge from exercising jurisdiction. The Oklahoma Supreme Court denied this writ.

Following the state court's decision, the defendants petitioned the U.S. Supreme Court for certiorari. The Supreme Court granted certiorari to address the constitutional question and resolve a conflict between the Oklahoma Supreme Court's ruling and decisions from the highest courts of at least four other states.

(White, J.)

No. Personal jurisdiction over out-of-state defendants in a products liability case cannot be established solely based on their product being involved in an accident within the forum state. The Due Process Clause of the Fourteenth Amendment requires that defendants have "minimum contacts" with the forum state for the exercise of jurisdiction to be constitutional. Mere foreseeability that a product might enter the forum state is insufficient. The critical consideration is whether the defendants' conduct and connection with the forum state are such that they should reasonably anticipate being haled into court there. Defendants must purposefully avail themselves of the privilege of conducting activities within the forum state, thus invoking the benefits and protections of its laws. In this case, the defendants had no activities in the forum state, closed no sales and performed no services there, and did not regularly sell products to customers in that state. The single product's presence in the state was a fortuitous circumstance, insufficient to establish the required minimum contacts. To hold otherwise would allow any state to exercise personal jurisdiction over a nonresident defendant wherever its products might foreseeably cause injury, regardless of the defendant's lack of connection to that forum. This would offend traditional notions of fair play and substantial justice and undermine the principles of interstate federalism embodied in the Constitution.

Dissent (Brennan, J.) The Court's view of minimum contacts is too narrow. The defendants' participation in the national automobile market and the foreseeability of their products being used in other states should be sufficient to establish jurisdiction. This approach better reflects the realities of modern commerce and ensures fair treatment of consumers harmed by products sold through nationwide distribution networks.

Dissent (Marshall, J.) The defendants' deliberate participation in a nationwide network for marketing and servicing automobiles should be sufficient to establish jurisdiction in Oklahoma. This interpretation better aligns with the evolving nature of interstate commerce and provides appropriate protections for consumers who are injured by products sold through national distribution channels. The majority's approach unduly restricts state court jurisdiction in product liability cases.

Dissent (Blackmun, J.) The unique nature of automobiles as inherently mobile products warrants a different jurisdictional analysis. It is not unreasonable to uphold Oklahoma jurisdiction over the New York distributor and dealer when the accident happened in Oklahoma. This approach recognizes the special characteristics of the automobile industry and ensures that injured parties have reasonable access to legal remedies in the state where the harm occurred.