Burger King Corp. v. Rudzewicz

471 U.S. 462 (1985)

A seminal United States Supreme Court opinion in the area of civil procedure/specific jurisdiction in which the Court determined that there was jurisdiction over a nonresident defendant even though not all of his controversy-related contacts occurred within the forum state.

The case involved Burger King’s breach of franchise agreement claims against Rudzewicz, a Michigan resident.  Rudzewich had negotiated the terms of that agreement with Burger King’s regional office in Michigan.  After Rudzewicz breached the agreement by failing to make payments required under the franchise agreement, Burger King filed a diversity action in a federal district court in Florida, the state of Burger King’s incorporation and principal place of business.

Even though Rudzewich had never visited Florida and the contract negotiations, etc., took place in Michigan, the Supreme Court held that he had sufficient contacts with Florida related to the controversy for the district court to exercise jurisdiction pursuant to Florida’s long-arm statute without running afoul the Due Process Clause of the Fourteenth Amendment.

The Court pointed to the following facts to support its ruling:

  • Rudzewich entered in the franchise agreement that specifically contained a Florida choice-of-law provision;
  • On several occasions, Rudzewich dealt directly with Burger King’s Florida headquarters; and
  • Rudzewich agreed to send the franchise payments to Burger King’s Florida address.

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