Hernandez v. Volkswagen Aktiengesellschaft CA1/4

CourtCalifornia Court of Appeal
DecidedMarch 21, 2025
DocketA168869
StatusUnpublished

This text of Hernandez v. Volkswagen Aktiengesellschaft CA1/4 (Hernandez v. Volkswagen Aktiengesellschaft CA1/4) is published on Counsel Stack Legal Research, covering California Court of Appeal primary law. Counsel Stack provides free access to over 12 million legal documents including statutes, case law, regulations, and constitutions.

Bluebook
Hernandez v. Volkswagen Aktiengesellschaft CA1/4, (Cal. Ct. App. 2025).

Opinion

Filed 3/21/25 Hernandez v. Volkswagen Aktiengesellschaft CA1/4 NOT TO BE PUBLISHED IN OFFICIAL REPORTS California Rules of Court, rule 8.1115(a), prohibits courts and parties from citing or relying on opinions not certified for publication or ordered published, except as specified by rule 8.1115(b). This opinion has not been certified for publication or ordered published for purposes of rule 8.1115.

IN THE COURT OF APPEAL OF THE STATE OF CALIFORNIA

FIRST APPELLATE DISTRICT

DIVISION FOUR

BLANCA HERNANDEZ et al. Plaintiffs and Appellants, A168869 v. VOLKSWAGEN (Alameda County AKTIENGESELLSCHAFT, Super. Ct. No. RG21102984) Defendant and Respondent.

Plaintiffs challenge the trial court’s order granting the motion to quash service of the summons on defendant Volkswagen Aktiengesellschaft (VWAG) for lack of personal jurisdiction. Plaintiffs argue that VWAG’s contacts with California are sufficient to support the trial court’s exercise of specific personal jurisdiction — in particular VWAG’s indirect but systematic efforts to serve the California market for Volkswagen cars and products through its exclusive importer Volkswagen of America, Inc. (VWoA). Plaintiffs further argue that their claims relate to these contacts, and VWAG fails to show that the exercise of personal jurisdiction over it would be unreasonable. We agree and reverse. BACKGROUND Per the operative complaint, plaintiffs are the widow and adult children of the deceased, Raul Hernandez (Hernandez), and plaintiff Blanca

1 Hernandez is his successor-in-interest under Code of Civil Procedure sections 377.11, 377.20, and 377.30. Plaintiffs allege that Hernandez died from mesothelioma, which he developed because of exposure to asbestos over a 40-year career as an automobile mechanic, including exposure to asbestos-containing brake shoes, brake pads, clutch plates, gaskets and transmission bands while working on Volkswagen cars between 1969 and 1976 at Volkswagen dealerships. Plaintiffs assert causes of action for strict products liability, negligence, and fraud against VWAG and its current New Jersey subsidiary, Volkswagen Group of America, Inc., among other defendants. VWAG specially appeared and filed a motion to quash service of summons (the motion), arguing that the court did not have personal jurisdiction over it because VWAG did not purposefully avail itself of the California market. VWAG contended that only VWoA, VWAG’s exclusive importer for the United States from 1956 to 1980, served the California market during the relevant time period. Along with its motion, VWAG submitted a declaration from its General Manager Corporate IP, Silke Katharina Reinhold, with the following information. VWAG is a German company with operations, including designing and manufacturing Volkswagen vehicles, in Germany; Volkswagen vehicles are “later exported [to] VWAG’s subsidiaries and/or independent importers throughout the world, including [VWoA].” From 1956 to 1980, VWAG did not conduct business in California; it was not registered, licensed or authorized to do business in California; it did not have a mailing address, telephone number, or agent for service of process in California; it did not own property or pay taxes in California; and it did not maintain any offices, or employ anyone, in California. VWAG “did not sell vehicles or genuine

2 Volkswagen replacement parts in California, nor did it implement or control any distribution system in California.” VWAG did not exercise day-to-day control over VWoA, any authorized Volkswagen distributor who sold cars to dealerships in California, or any authorized Volkswagen dealership in California. VWAG did not direct or control VWoA’s decisions concerning which vehicles VWoA would sell into California. Finally, VWAG did not design or manufacture vehicles or genuine replacement parts “exclusively for the California market.” Plaintiffs opposed the motion and sought jurisdictional discovery. In support of their opposition, plaintiffs submitted the following evidence that they argued established purposeful availment: a VWAG corporate history document from 2015 entitled, “ ‘From the Beetle to a Global Player. Volkswagen Chronicle’ ”; excerpts from VWAG’s Annual Reports from the 1960s and 1970s; deposition testimony from VWAG’s corporate representative in another case, along with some importer agreements between VWAG and VWoA; California Air Resource Board (CARB) exhaust- emission certificates for Volkswagen cars from the 1970s; and 1986 correspondence on VWoA letterhead to the EPA discussing asbestos regulation and asbestos use in Volkswagen products. Plaintiffs argued that VWAG and its subsidiaries purposefully supplied Volkswagen products to California. The trial court continued the motion to allow for limited jurisdictional discovery. After completing a round of written jurisdictional discovery, plaintiffs filed supplemental opposition papers. They argued their “most significant” new evidence was the VWAG-VWoA importer agreements from 1967, 1969, 1971, and 1973 (the importer agreements, or contracts), which showed

3 purposeful availment because they established that VWAG and VWoA together purposefully supplied the California market with Volkswagen vehicles and replacement parts. Plaintiffs highlighted that the contracts: (1) made VWoA the exclusive supplier for Volkswagen products in Alaska, Hawaii, and the continental United States, including California; (2) required VWoA to promote and sell Volkswagen products in California; and (3) dictated that VWoA was required to establish office employees and business fieldmen and to set up a dealership network for solicitation.1 Alternatively, plaintiffs requested leave to pursue written discovery and a deposition on certain topics, including VWAG and VWoA statements and inter-company communications regarding the California market, California dealer network, and California service network for Volkswagen products. The trial court again continued the motion to allow for additional limited jurisdictional discovery with the following observations: while language in the importer agreements “required VWoA to establish facilities to solicit sales of Volkswagen vehicles to ‘all potential customers’ in the United States . . . [that] requirement [was not] sufficient to show VWAG’s purposeful availment of the California market within the meaning of case law.” Nonetheless, the court observed that Articles 3 and 5 of the importer agreements allowed VWAG to retain some control over how VWoA conducted

1 In their opposition papers below, plaintiffs also argued that

purposeful availment was established by (1) CARB executive orders approving exhaust emissions control systems for Volkswagen cars sold in California and related evidence regarding the development of emissions testing standards; (2) reports showing that VWAG conducted audits on the business of Vorelco of California, a subsidiary of VWoA based in California; and (3) evidence relating to the shipment of Volkswagen cars into California. Given our disposition, we need not discuss this evidence in detail or address the trial court’s determinations with respect thereto.

4 business, so the court allowed written discovery regarding inter-company communications between VWAG and VWoA regarding the market, dealership network, and service network in California during the relevant period. Plaintiffs filed another set of supplemental opposition papers following written discovery, including a 1972 VWoA monthly market report to VWAG and a 1974 VWoA letter sending VWoA’s yearly financial statements to VWAG. After hearing argument, the trial court ruled on the motion.

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Bluebook (online)
Hernandez v. Volkswagen Aktiengesellschaft CA1/4, Counsel Stack Legal Research, https://law.counselstack.com/opinion/hernandez-v-volkswagen-aktiengesellschaft-ca14-calctapp-2025.