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Burger King v. Rudzewicz

Burger King v. Rudzewicz, 471 U.S. 462 (1985), is a notable case in United States civil procedure that came before the Supreme Court of the United States.

Facts

Two Michigan residents (John Rudzewicz and Brian MacShara, the defendants) entered into an agreement with Burger King to run a franchise. The two defendants would pay their franchise fees and royalties to Burger King's Florida headquarters. One of the defendants also attended training courses at regional Burger King University locations and in the Florida headquarters on how to run a Burger King franchise. The defendants were unable to make their monthly payments to Burger King, prompting the Florida-based corporation to file a lawsuit in Florida for breach of contract and tortious infringement of Burger King's trademarks and servicemarks through the defendants' unauthorized operation as a Burger King restaurant after the defendants received notice to vacate the premises.

Procedure

The District Court held that Florida had jurisdiction because of a statute that allowed the state to extend jurisdiction to anyone breaching a contract within the state. The United States Court of Appeals for the Eleventh Circuit reversed the lower court's decision finding that even though the defendants had minimum contacts with Florida, to exercise jurisdiction over the defendants would be fundamentally unfair and thus violate the due process clause of the Fourteenth Amendment. Burger King then appealed to the Supreme Court.

Holding

The Supreme Court concluded that the defendants purposefully availed themselves of the protections of the forum state (Florida) and were, therefore, subject to jurisdiction there. The Court reasoned that the defendants had a "substantial and continuing" relationship with Burger King in Florida and that due process would not be violated because the defendants should have reasonably anticipated being summoned into court in Florida for breach of contract.

Dissent

In dissent, Justice John Paul Stevens argued that Rudzewicz had never been to Florida and had no business established in Florida. Rudzewicz could not have anticipated being summoned into court in Florida, and it violates the due process clause to require a small businessman in Michigan to have to make an appearance in a court in Florida to present his defense.