Law School Case Brief
Burger King Corp. v. Rudzewicz - 471 U.S. 462, 105 S. Ct. 2174 (1985)
Once it has been decided that a defendant purposefully established minimum contacts within the forum state, these contacts may be considered in light of other factors to determine whether the assertion of personal jurisdiction would comport with fair play and substantial justice.
A Florida corporation with principal offices in Miami and which conducted most of its restaurant business through a franchise operation brought an action for breach of contract in Florida against two franchisees, Michigan residents, alleging that these franchisees had breached the franchise agreement for their restaurant, located in Michigan. The district court denied the defendants' motion to dismiss for lack of in personam jurisdiction, ruling that pursuant to Florida's long-arm statute, a nonresident franchisee of the plaintiff was subject to in personam jurisdiction in Florida in actions arising out of its franchise agreement. The court subsequently entered judgment against the defendants. One defendant appealed to the United States Court of Appeals for the Eleventh Circuit, which reversed the judgment, concluding that the district court could not properly exercise personal jurisdiction pursuant to the long-arm statute because the circumstances of the franchise and the negotiations which led to it left the defendants bereft of reasonable notice and financially unprepared for the prospect of franchise litigation in Florida.
Did the Florida federal district court have personal jurisdiction over the franchisees under Florida's long-arm statute?
The United States Supreme Court held that Florida courts had jurisdiction under the Florida long-arm statute because a party that avails itself of the protections and benefits of the law of a forum state is subject to personal jurisdiction of that state. The Court found that the appellees had entered into a contract and established a substantial and continuing relationship with the appellant, a Florida resident. The Court further found that the appellee had fair notice that he might be subject to suit in Florida. The court further found that the exercise of jurisdiction would not offend due process and reversed the holding of the court of appeals and remanded for further proceedings.
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