Burger King Corp. v. Rudzewicz
Parties: Defendant: Rudzewicz, a former franchisee of a Burger King in Michigan.
Facts: Rudzewicz entered into a twenty year contract to maintain a Burger King franchise in Michigan. Defendant entered into contracts with district office in Michigan as well as the national HQ in Miami. Later that year, defendant fell far behind in monthly payments which eventually led to termination of the franchise deal. Plaintiff ordered defendant to vacate the restaurant, which order defendant refused.
Procedural History: Burger King filed action in the District Court for the District of S. Florida. District Court determined that it had jurisdiction over the defendant. Defendant Appealed. 11th Cir. Ct. reversed the judgment.
Issues:
- Whether the defendant purposefully established "minimum contacts" in the forum State.
- Whether jurisdiction over the defendant comports with "fair play and substantial justice."
Arguments: Defendant argued that Michigan's Franchise Laws govern many aspects of franchise. (The court replied that this in no way renders Florida jurisdiction unconstitutional.)
Holding: The court in question has jurisdiction over the defendant.
Reasons:
- Defendant established minimum contacts in Fla. by virtue of his 20 year agreement with the plaintiff. The continuing contractual obligations created by the defendant constitutes action by which "the defendant purposefully avails itself of the privilege of conducting activities within the forum state, thus invoking the benefits and protections of its laws."
- There are five considerations used to determine reasonableness. Defendant received fair notice from contract, and "failed to demonstrate how jurisdiction would otherwise be . . . unfair."
Judgment: Reversed and remanded.
Comments: The burden to prove unconstitutionality turned to the defendant once it was shown that minimum contact existed and that jurisdiction was fair and just.
