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Burger King v. Rudzewicz

From lawbrain.com

Burger King Corp. v. Rudzewicz, 471 U.S. 462, 105 S. Ct. 2174, (1985), is a landmark civil procedure case holding that jurisdiction is proper when the defendant’s contact proximately results from actions by the defendant such that they create a substantial connection with the forum state.

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Contents

Summary of Case Facts

The defendant (Rudzewicz) entered into a franchise agreement with plaintiff (Burger King Corp.) to open a Burger King Franchise in Michigan. Plaintiff was headquartered and incorporated in Florida. The franchise agreement included a choice of law clause in the contract that indicated that Florida law would control for litigation purposes. The franchise contract stated that defendant be allowed to use Burger King’s trademarks and service marks for twenty years in Michigan. All financial obligations owed to Burger King were to be sent to Florida and defendant was to receive training for running the Burger King franchise in Florida. Rudzewicz failed to meet his obligations under the contract because of an economic downturn that led to decreased sales. Burger King brought a diversity suit against defendant in the Southern District of Florida. Rudzewicz moved to dismiss the case on the grounds that the court did not have personal jurisdiction because they did not have sufficient minimum contacts with Florida.

Issue

Whether the Florida court has personal jurisdiction over the defendant, Rudzewicz.

Holding and Law

Yes, the Florida court has personal jurisdiction over the defendant. In order for the court to have personal jurisdiction over the defendant, it must be shown that the defendant has established a substantial and continuous relationship with Florida. The defendant received fair notice from the franchise documents and the course of the dealing that he might be subject to suit in Florida. The plaintiff must also demonstrate how jurisdiction in Florida would otherwise be fundamentally unfair. The Burger King Franchise agreement allowed defendant to benefit from an association with a Florida corporation for twenty years. Defendant had continuing and direct contacts with Burger King. The franchise agreement indicated that Florida law would apply. The defendant had not shown that he would be unfairly prejudiced or harmed by a trial in Florida.

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