World-Wide Volkswagen Corp. V. Woodson

World-Wide Volkswagen Corp. v. Woodson

Facts: In 1976, Harry and Kay Robinson purchased a new Audi automobile from Seaway Volkswagen, Inc (Seaway) in Massena, N.Y. The following year the Robinson family, who resided in New York, left that state for a new home in Arizona. As they passed through Oklahoma, another car struck their Audi in the rear, causing a fire which severely burned Kay Robinson and her two children. The Robinsons subsequently brought a products-liability action in the District Court for Creek County, Oklahoma, claiming that their injuries resulted from defective design and placement of the Audi’s gas tank and fuel system. They brought suit against the automobile’s manufacturer (Audi), its importer (Volkswagen of America), its regional distributor (World-Wide Volkswagen Corp.), and its retailer dealer (Seaway Volkswagen). The Supreme Court of Oklahoma held that personal jurisdiction over the defendents was authorized by Oklahoma’s long-arm statute.

Issue: Can the Oklahoma court exercise personal jurisdiction over nonresident defendants given that “minimum contacts” with the State may or may not exist?

Decision: In favor of World-Wide. The judgment of the Supreme Court of Oklahoma is reversed.

Reason: The concept of minimum contacts between the petitioners and the State of Oklahoma does not hold. World Wide and Seaway have no “contacts, ties, or relations” with the State of Oklahoma. They carry on no activity whatsoever in Oklahoma. They close no sales and perform no services there. They avail themselves of none of the privileges and benefits of Oklahoma law. They solicit no business there either through salespersons or through advertising reasonably calculated to reach the State. They do not sell regularly cars at wholesale or retail to Oklahoma customers or residents. In short, World Wide and Seaway have insufficient ties with the State of Oklahoma, therefore Oklahoma courts cannot practice in personam jurisdiction against them.

Case Brief 3.3
Parker v. Twentieth Century-Fox Corp.

Facts: Shirley MacLaine Parker contracted with the film company, Twentieth Century-Fox, to play the female lead in a musical motion picture entitled “Bloomer Girl.” Parker was to be paid $750,000 for the role. Prior to the start of the film, Fox informed Parker that that they would not be producing “Bloomer Girl.” Fox offered Parker the lead in another film, a dramatic western entitled “Big Country, Big Man.” The compensation was to be the same - $750,000. Parker was given one week to accept and she refused. Parker then sought recovery of agreed upon compensation. The trial court granted summary judgment to Parker. Fox appealed. Issue: Was the job that Fox offered Parker (i.e. “Big Country”) comparable employment and was Parker obligated to accept in order to mitigate damages?

Decision: In favor of Parker. The trial court’s summary judgement was affirmed.

Reason: Parker’s refusal to accept Fox’s substitute employment offer could not be applied in mitigation of damages. This is because the offer of the “Big Country” lead was of employment both different and inferior. The fact that “Bloomer Girl” was to be a musical calling upon Parker’s talents as a dancer as well as an actress, and was to be produced in California, whereas “Big Country” was a straight dramatic role in a western type story taking place in Australia, demonstrates the difference in kind between the two employments. Parker was under no obligation to accept the inferior role and was not unreasonable in her refusal to mitigate the damages.

Case Brief 4.3
Granholm v. Heald

Facts: Michigan and New York laws allowed in-state wineries to directly ship alcohol to consumers but restricted the ability of out-of-state wineries to do so. In several cases, some Michigan residents and some out-of-state wineries, joined by their New York customers, brought suit against the two states, arguing that the laws unfairly favor in-state...
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