## Facts

- Burger King Corporation, headquartered in Miami, Florida, operated primarily through long-term franchise agreements.
- John Rudzewicz, a Michigan resident, and a business associate entered a 20-year franchise agreement to operate a Burger King restaurant in Michigan.
- The franchise documents stated the franchise relationship was established in Miami and governed by Florida law.
- The agreements required franchisees to send monthly payments and relevant notices to Burger King’s Miami headquarters.
- Burger King’s Miami headquarters handled franchise policy and major dispute resolution; day-to-day monitoring occurred through a Michigan district office that reported to Miami.
- After business declined, the franchisees fell behind on payments; negotiations involving the franchisees, the Michigan district office, and Miami headquarters failed.
- Burger King terminated the franchise and demanded the franchisees vacate; they refused and continued operating the restaurant.
- Burger King sued in federal court in Florida for breach of contract and sought damages and injunctive relief.

## Issues

1. Whether a Florida federal court’s exercise of specific personal jurisdiction over a Michigan franchisee based on the franchise relationship and contract terms satisfies due process.
2. Whether the franchisee purposefully established minimum contacts with Florida through negotiations, contract terms, and an ongoing course of dealing.
3. Whether exercising jurisdiction in Florida would be unreasonable under “fair play and substantial justice” considerations.

## Decision

- The Supreme Court reversed the Eleventh Circuit and upheld the Florida district court’s exercise of personal jurisdiction.
- The Court held that the franchisee purposefully established substantial, continuing contacts with Florida by entering a long-term franchise relationship centered on Burger King’s Florida headquarters.
- The Court concluded the franchisee had fair warning that he could be sued in Florida given the Florida-centered obligations and ongoing interactions.
- The Court held jurisdiction was not unreasonable because litigating in Florida was not so gravely difficult as to be constitutionally unfair, and Florida had an interest in adjudicating disputes involving a Florida franchisor.
- A dissent would have found jurisdiction unfair given the franchisee’s lack of physical presence in Florida and the perceived imbalance in bargaining power.

## Legal Principles

- Due process permits specific jurisdiction when the claim arises out of or relates to the defendant’s forum-directed conduct and jurisdiction does not offend traditional notions of fair play and substantial justice.
- A contract with a forum resident does not automatically establish minimum contacts; courts assess prior negotiations, contemplated future consequences, contract terms, and the parties’ actual course of dealing.
- The relevant foreseeability is whether the defendant’s own conduct makes it reasonable to anticipate being haled into court in the forum.
- Once purposeful availment is shown, jurisdiction is presumptively constitutional; the defendant must make a compelling case that fairness factors render jurisdiction unreasonable.
- Fairness factors include the burden on the defendant, the forum state’s interest, the plaintiff’s interest in effective relief, efficiency, and shared state interests.
- A choice-of-law clause favoring the forum supports purposeful availment but is not dispositive standing alone.

## Conclusion

The Court held that a Michigan franchisee’s deliberate entry into a long-term, Florida-governed franchise relationship with ongoing Florida-directed obligations created sufficient minimum contacts for specific jurisdiction, and the fairness factors did not make Florida’s exercise of jurisdiction unconstitutional.


Burger King Corp. v. Rudzewicz, 471 U.S. 462 (1985)