Burger King v. Rudzewicz
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| Burger King v. Rudzewicz | |||||||||||||
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| Argued January 28, 1985 Decided May 20, 1985 |
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| Holding | |||||||||||||
| The District Court's exercise of jurisdiction pursuant to Florida's long-arm statute did not violate the Due Process Clause of the Fourteenth Amendment. | |||||||||||||
| Court membership | |||||||||||||
| Chief Justice: Warren E. Burger Associate Justices: William J. Brennan, Byron White, Thurgood Marshall, Harry Blackmun, Lewis Franklin Powell, Jr., William Rehnquist, John Paul Stevens, Sandra Day O'Connor |
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| Case opinions | |||||||||||||
| Majority by: Brennan Joined by: Burger, Marshall, Blackmun, Rehnquist, O'Connor Dissent by: Stevens Joined by: White Powell took no part in the consideration or decision of the case. |
Burger King v. Rudzewicz, 471 U.S. 462 (1985)[1], is a notable case in United States civil procedure that came before the Supreme Court of the United States.
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[edit] Facts
Two Michigan residents (John Rudzewicz and Brian MacShara, the defendants) entered into an agreement with Burger King to run a franchise. The two defendants would pay their franchise fees and royalties to Burger King's Floridian headquarters. One of the defendants also attended training in Florida on how to run a Burger King franchise. The defendants were unable to make their monthly payments to Burger King, prompting the Florida-based corporation to file a lawsuit in Florida for breach of contract and tortious infringement of Burger King's trademarks and servicemarks through the defendants' unauthorized operation as a Burger King restaurant after the defendants received notice to vacate the premises.
[edit] Procedure
The District Court held that Florida had jurisdiction because of a statute that allowed the state to extend jurisdiction to anyone breaching a contract within the state. The United States Court of Appeals for the Eleventh Circuit reversed the lower court's decision finding that even though the defendants had minimum contacts with Florida, to exercise jurisdiction over the defendants would be fundamentally unfair and thus violate the due process clause of the Fourteenth Amendment. Burger King then appealed to the Supreme Court.
[edit] Holding
The Supreme Court concluded that the defendants purposefully availed themselves to the protections of the forum state (Florida) and are, therefore, subject to jurisdiction there. The Court reasoned that the defendants had a "substantial and continuing" relationship with Burger King in Florida and that due process would not be violated because the defendants should have reasonably anticipated being summoned into court in Florida for breach of contract.
[edit] Dissent
In dissent, Justice John Paul Stevens argued that Rudzewicz had never been to Florida and had no business established in Florida. Rudzewicz could not have anticipated being summoned into court in Florida, and it violates the due process clause to require a small businessman in Michigan to have to make an appearance in a court in Florida to present his defense.
[edit] References
- ^ 471 U.S. 462 Full text of the opinion courtesy of Findlaw.com.
