A State Court’s Personal Jurisdiction Over Non-Resident Defendant

A State Court’s Personal Jurisdiction Over Non-Resident Defendant Whose Sole Connection is the Accident   A state court may not exercise in personam jurisdiction over a non-state resident defendant in a products liability action where the defendant’s only connection to the state is the accident in question. This matter was conclusively settled by a majority 6-3 decision of the US Supreme Court in World-Wide Volkswagen Corp.

v. Woodson,  444 U.S. 286 (1980).  The decision was justified on the ground that the state court’s exercise of in personam jurisdiction where the accident was the sole link would be in violation of the Due Process Clause of the Fourteenth Amendment. The Due Process provision restricts the power of state court to issue a valid personal judgment against a defendant who is not a resident of the forum state.

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Such personal jurisdiction can only suffice in very limited circumstances.   The limited circumstances are where a ‘minimum contacts’ test has been satisfied. The contact under consideration is that of the defendant in relation to the court of the forum state. The Woodson decision, therefore, reiterated that a state court may only have such jurisdiction where a ‘minimum contacts’ is met. The test has two limbs. The first involves ascertaining whether there is a federal or state rule of procedure or legislation that grants the state court jurisdiction under the alleged facts and specific circumstances of the case.

The absence of such a law automatically defeats a claim of personal jurisdiction while its presence triggers the application of the second limb. Hence, the second is whether the circumstances of the case satisfy the procedural due process standards of the state and federal constitutions respectively. In this case, although there is a state statute that satisfies the first limb, the Woodson decision held that the accident in question being the sole link between the defendant and the forum state did not meet the minimum contacts threshold and, thus, in violation of the 14th Amendment.


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