Civil Procedure

Brief

Burger King Corp. v. Rudzewicz

Procedural History:

• District Court holds for P.
  • D Appeals
• Ct. of appeals reversed.
  • P appeals.
• Supreme Court Reversed to original ruling from Trial Court.

Facts:

• BK Corporation’s principle offices are in Miami.
• BK conducts most of its business through franchises.
• D enters into a 20 year contract with BK to own and operate a franchise in Michigan.
• The contract provides that the relationship between P and D is established in Miami and governed by Florida Law.
• All fees and monthly payments must be forwarded to the Miami headquarters.
• D falls behind in monthly payments.
• Negotiations between P and D fail and D is asked to leave the premises.
• D refuses and continues to operate the restaurant.
• P sues D in Florida court.
• D claims lack of personal jurisdiction.

Issue:

• Does Florida have personal jurisdiction over D without offending due process?

Holding:

• Yes. There were minimum contacts in Florida which is the forum state.

Reasoning:

• Throughout the process, D negotiated with the Florida offices. The contract grew out of a connection that D had with the state of Florida and BK Corp and he dealt directly with them via phone and continued contact. He voluntarily accepted the regulations of his business from BK Miami headquarters.
• The contract D signed with BK explicitly stated that Florida law would govern it.