Burger King v. Rudzewicz
Citation: 471 U.S. 462 (1985)
Facts
Rudzewicz, a Michigan resident, entered into a franchise agreement with Burger King, headquartered in Florida. The contract contained a Florida choice-of-law clause. When the franchise failed, Burger King sued in Florida. Rudzewicz argued no personal jurisdiction.
Issue
Did Rudzewicz have sufficient minimum contacts with Florida to support personal jurisdiction, notwithstanding that he never physically entered the state?
Holding
Yes. Rudzewicz purposefully availed himself of the privileges of doing business in Florida through his deliberate, long-term contractual relationship with a Florida-based corporation, including negotiating with Florida headquarters and agreeing to Florida law.
Rule
A defendant who has deliberately engaged in a significant course of dealing with a party in the forum state — particularly through an ongoing contractual relationship — has purposefully availed itself of that forum even without physical presence. The contract is a contact, but courts look at the prior negotiations, contemplated future consequences, the contract’s terms, and the parties’ course of dealing.
Significance
- Confirms that physical presence in the forum is not required — deliberate contractual ties suffice
- Shows that choice-of-law provisions and the parties’ course of dealing are relevant contacts for jurisdiction purposes
- Important limitation: the mere existence of a contract with a forum-state party is not sufficient by itself — the contract must reflect purposeful availment
- Frequently paired with World-Wide Volkswagen and Asahi in personal jurisdiction analysis