Burger King Corp. v. Rudzewicz

Burger King Corp. v. Rudzewicz

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Court	Supreme Court of the United States
Full case name
Argued
Reargued
Submitted
Indictment
Started
Decided
Verdict
Defendant

Burger King Corp. v. Rudzewicz is a landmark case decided by the Supreme Court of the United States in 1985. The case involved a dispute between Burger King Corporation (BKC) and John Rudzewicz, a Michigan resident who operated a Burger King franchise in Florida. This case is significant in establishing the principles of personal jurisdiction in the context of long-arm statutes.

Background

In the late 1970s, BKC entered into a franchise agreement with Rudzewicz, granting him the right to operate a Burger King restaurant in Florida. The agreement contained a provision stating that it would be governed by the laws of the state of Florida. However, Rudzewicz failed to make required payments to BKC, leading to the termination of the franchise agreement.

BKC subsequently filed a lawsuit against Rudzewicz in federal district court in Florida, seeking damages for breach of contract. Rudzewicz argued that the court did not have personal jurisdiction over him, as he was a resident of Michigan and had no substantial contacts with Florida.

Legal Proceedings

The district court ruled in favor of BKC, finding that it had personal jurisdiction over Rudzewicz based on Florida's long-arm statute. The long-arm statute allowed the court to exercise jurisdiction over non-residents who had sufficient minimum contacts with the state.

Rudzewicz appealed the decision to the United States Court of Appeals for the Eleventh Circuit, which affirmed the district court's ruling. He then petitioned the Supreme Court for review.

Supreme Court Decision

The Supreme Court, in a unanimous decision, upheld the lower courts' rulings and held that the Florida court had personal jurisdiction over Rudzewicz. Justice Byron White, writing for the majority, outlined the principles for determining personal jurisdiction in cases involving long-arm statutes.

The Court established a two-pronged test for determining personal jurisdiction: (1) the defendant must have minimum contacts with the forum state, and (2) the exercise of jurisdiction must be consistent with traditional notions of fair play and substantial justice.

In applying this test to the case, the Court found that Rudzewicz had purposefully availed himself of the privilege of conducting activities in Florida by entering into the franchise agreement. Furthermore, the Court determined that the exercise of jurisdiction over Rudzewicz was fair and reasonable, considering the nature of the dispute and the convenience of the parties.

Impact

Burger King Corp. v. Rudzewicz clarified the standards for personal jurisdiction in cases involving long-arm statutes. The decision emphasized the importance of a defendant's voluntary actions and contacts with a particular state in determining whether a court has jurisdiction over them.

This case has since been cited in numerous subsequent decisions, shaping the understanding and application of personal jurisdiction in the United States legal system.

See also

• Personal jurisdiction
• Long-arm statute
• Supreme Court of the United States