Key points The Robinson family, while residents of NY, purchased a new Audi from Seaway in NY/1976 1977, they relocated to Arizona While traveling to.

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Presentation transcript:

Key points The Robinson family, while residents of NY, purchased a new Audi from Seaway in NY/1976 1977, they relocated to Arizona While traveling to Arizona, they passed through the State of Oklahoma In Oklahoma, the Robinson car was rear-ended by another vehicle, causing the fuel tank to explode and resulting in severe burns to Ms Robinson and her 2 children

Robinson Car (These 2 pics. can be used as examples for Clarity) Audi 100 LS

Lloyd Hull -1971 Ford Torino

The Parties Robinson family: Harry & Kay Robinson, their 2 children Woodson: Judge of District Court DEFENDANTS Worldwide: Regional distributor for Volkswagen of America. Head office located in NY. Served tri-state area: NY, NJ, CT Seaway: Volkswagen dealership (located in Massena, NY) bought the Audi 100 LS from Worldwide Audi Auto Nation: Manufacturer of Audi Volkswagen of America, Inc: Importer for Audi Auto Nation

Points of View (Also counted as Breadth examples)

Robinson Family The Robinsons did not file a lawsuit against Lloyd Hull (drunk driver) because he had no insurance/assets. Brought a product liability act against: Audi Auto Union Volkswagen of America, Inc. World-Wide Seaway Robinson’s Point of View: “The design and placement of the fuel tank was the cause of our injuries.”

Worldwide/Seaway Volkswagen POV: Oklahoma District/Supreme Court are violating our 14th amendment rights. “Minimum contacts must be based on some act committed by the defendant therefore, the State of Oklahoma does not have jurisdiction over us because we…” Did not do business (sell, repair, advertise) in Oklahoma Did not seek to do business in Oklahoma Limited our activities to tri-state area (NY, NJ, CT)

District Court (Creek County, Oklahoma) Woodson POV: asserted in personam jurisdiction over all defendants and rejected the arguments of World-Wide and Seaway.

Federal Court of Oklahoma Worldwide/Seaway Volkswagen appealed decision, asking Federal Court to deny Woodson from asserting jurisdiction over them. Ruling: Federal Court used the Long-Arm Statute, granting jurisdiction to Oklahoma state court over out of state (NY) defendants. POV: “Cars are mobile; easy to foresee their use in other States.”

NO CONTACTS + NO RELATIONS = NO JURISDICTION! U.S Supreme Court The US Supreme Court granted certiorari to review. Supreme Court POV: “Oklahoma lacked affiliating circumstances with non-resident defendants to exercise jurisdiction over them.” Worldwide/Seaway did not do any business in Oklahoma and foreseeability alone is insufficient as a basis for jurisdiction. NO CONTACTS + NO RELATIONS = NO JURISDICTION!

(Disagreeing w/Supreme Court) Other POV (Disagreeing w/Supreme Court) Brennan States may exercise jurisdiction over a defendant even if that party has not deliberately or purposefully sought contact with the state. It would be difficult to believe that the defendants truly believed that none of the cars they sold would ever leave the New York area. Their contacts with Oklahoma were not extensive but it was reasonable for them to be subjected to jurisdiction. Fairness dictates that the sale of a mobile item such as a car should satisfy the minimum contacts necessary for jurisdiction.

Economic POV More of a financial burden for the Robinson family to file case in NY

Main legal issue (Counted as 1 point for Logic standard) In order to exercise personal jurisdiction over a nonresident party, how extensive must the party’s contacts be to satisfy due process?

Significance standard This ruling reaffirmed due process and minimal contact