Burger King Corp. v. Rudzewicz

85 L. Ed. 2d 528 · Supreme Court of the United States · 1985

Facts

Burger King, a Florida corporation, sued John Rudzewicz, a Michigan franchisee, in Florida federal court for breach of a franchise agreement and trademark infringement. Rudzewicz had failed to make required payments to Burger King's Miami headquarters. The District Court found personal jurisdiction, but the Court of Appeals reversed, stating jurisdiction would offend due process.

Issue

Does the Due Process Clause permit a federal court in Florida to exercise personal jurisdiction over a Michigan franchisee who breached a long-term franchise agreement with a Florida-based franchisor by failing to make payments in Florida?

Holding

Yes, the Supreme Court reversed the Court of Appeals, holding that the exercise of personal jurisdiction over Rudzewicz in Florida did not offend the Due Process Clause because he had established sufficient minimum contacts with the state.

Rule

Personal jurisdiction over an out-of-state defendant requires that the defendant purposefully established minimum contacts with the forum state, such that they should reasonably anticipate being haled into court there. This involves evaluating prior negotiations, contemplated future consequences, contract terms, and the parties' actual course of dealing, ensuring it comports with fair play and substantial justice.

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