Burger King Corp. v. Rudzewicz
Citation: 471 U.S. 462 (U.S. Supreme Court, 1985)
Facts
Rudzewicz, a Michigan resident, entered into a franchise agreement with Burger King, a Florida corporation. The contract contained a choice-of-law clause specifying Florida law and required Rudzewicz to send payments to Burger King’s Miami headquarters. After a dispute, Burger King sued Rudzewicz in federal court in Florida. Rudzewicz argued Florida lacked personal jurisdiction over him.
Issue
Whether Florida could exercise personal jurisdiction over a Michigan franchisee who had never physically been in Florida but had entered into a long-term franchise relationship with a Florida corporation and was subject to Florida law by contract.
Holding
The Supreme Court held that Florida had personal jurisdiction over Rudzewicz. By entering into a long-term contractual relationship with a Florida company, negotiating with Florida headquarters, and agreeing to a Florida choice-of-law clause, Rudzewicz purposefully availed himself of the privilege of conducting activities in Florida.
Rule
Purposeful availment may be established through a contractual relationship if the defendant reached out to the forum and engaged in a continuing relationship with a forum-based entity. A contract alone does not automatically establish jurisdiction — courts must look at the prior negotiations, contemplated future consequences, the terms of the contract, and the parties’ actual course of dealing.
Significance
Burger King is the key case on purposeful availment in the contractual context. It establishes that physical presence in the forum is not required and that a deliberate, continuing business relationship can satisfy the minimum contacts standard, while also clarifying that a mere contract with a forum resident is not automatically sufficient.