Burger King Corp. v. Rudzewicz

Summary

The Supreme Court held that exercising specific personal jurisdiction in Florida over a Michigan franchisee did not violate the Due Process Clause. The franchisee purposefully established substantial and continuing contacts with Florida through a long-term relationship with Burger King's Miami headquarters, including contractual provisions selecting Florida law and requiring payments and notices to be sent there.

Holdings

1. An appeal under 28 U.S.C. § 1254(2) does not properly lie unless the court of appeals clearly and independently held that a state statute is unconstitutional on its face or as applied; a judgment based on a stipulated construction of state law is insufficient.
2. A defendant who purposefully establishes minimum contacts with a forum through deliberate, continuing, and substantial commercial relationships may be subject to specific personal jurisdiction there when the litigation arises out of or relates to those activities.
3. A contract with an out-of-state party does not automatically establish minimum contacts, but courts must take a highly realistic approach evaluating prior negotiations, contemplated future consequences, contract terms, and the parties' actual course of dealing.
4. Once purposeful minimum contacts are established, jurisdiction is presumptively reasonable, and the defendant must present a compelling case that other considerations make jurisdiction unreasonable.
5. Florida's exercise of personal jurisdiction over Rudzewicz under Fla. Stat. § 48.193(1)(g) did not violate the Due Process Clause.

Questions Presented

1. Whether the Supreme Court had appellate jurisdiction under 28 U.S.C. § 1254(2) when the Eleventh Circuit had not clearly held Florida's long-arm statute unconstitutional.
2. Whether exercising specific personal jurisdiction over a Michigan franchisee in Florida comported with the Due Process Clause of the Fourteenth Amendment.
3. Whether a contractual relationship, considered together with prior negotiations, contemplated future consequences, contract terms, and the parties' actual course of dealing, established purposeful availment and minimum contacts.
4. Whether Florida's exercise of jurisdiction was unreasonable under the fair-play-and-substantial-justice factors.

Disposition

reversed_and_remanded