Burger King Corp. v. Rudzewicz
85 L. Ed. 2d 528 · Supreme Court of the United States · 1985
Facts
Burger King, a Florida corporation, sued its Michigan franchisee, John Rudzewicz, in Florida for breach of contract and trademark infringement after he failed to make required payments. Rudzewicz challenged personal jurisdiction, arguing he lacked sufficient contacts with Florida. The franchise agreement stipulated Florida law and required payments to Miami headquarters.
Issue
Does the Due Process Clause permit a Florida federal court to exercise personal jurisdiction over a Michigan franchisee who breached a contract with a Florida franchisor, given the contractual ties and course of dealing?
Holding
Yes, the exercise of personal jurisdiction over the Michigan franchisee in Florida did not offend due process because he purposefully established a substantial and continuing relationship with the Florida franchisor. The Court reversed the Eleventh Circuit's judgment.
Rule
Personal jurisdiction requires a defendant to have purposefully established minimum contacts with the forum state, such that they should reasonably anticipate being haled into court there. This is determined by evaluating prior negotiations, contemplated future consequences, contract terms, and the parties' actual course of dealing, along with other factors for fair play and substantial justice.
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