Burger King Corp. v. Rudzewicz

Summary

**Burger King Corp. v. Rudzewicz, 471 U.S. 462 (1985)** – Personal jurisdiction; due process; minimum contacts; long-arm statute; franchise agreement; purposeful availment. The Supreme Court held that a Florida court could constitutionally exercise specific personal jurisdiction over a Michigan franchisee who deliberately entered a long-term franchise relationship with a Florida corporation, where the contract required payments and notices to Miami, the parties had ongoing direct communications with Miami headquarters, and the franchisee received fair notice of potential suit in Florida from contract terms and course of dealing. The Court rejected a mechanical contract-as-contact test, requiring evaluation of prior negotiations, contemplated future consequences, contract terms, and actual dealings to determine purposeful availment. Choice-of-law provisions, while not alone sufficient, may reinforce a defendant's deliberate affiliation with the forum state. The decision reversed the Eleventh Circuit's finding that jurisdiction would offend due process.

Holdings

1. The exercise of jurisdiction did not violate due process because Rudzewicz purposefully established minimum contacts with Florida by entering into a franchise agreement that created a substantial and continuing relationship with Burger King's Miami headquarters, and he received fair notice that he might be subject to suit in Florida.

Questions Presented

1. Whether the exercise of personal jurisdiction over a Michigan franchisee in Florida, pursuant to Florida's long-arm statute, violated the Due Process Clause of the Fourteenth Amendment.

Disposition

reversed_and_remanded