Burger King Corp v Rudzewicz

1985

Venue: SCOTUS

Facts: Rudzewicz is a senior partner in a DET accounting firm. He gets into a dranchise deal for Burger King, which is in FL. There are long and intense negotiations, and it's not clear that the parties agreed about stuff. After the agreement is signed, the business deteriorates, and payments fall behind.

Posture: Suit in FL district court with diversity and trademark jurisdiction. Rudzewicz challenges personal jurisdiction, and the district court rejects the challenge. Verdict for BK at trial, 11th Cir reverses for lack of personal jurisdiction.

Issue: So is there jurisdiction or what?

Holding: Yes. Reversed.

Rule: If you purposefulle direct your acivities at forum residents, it's hard to dispute jurisdiction.

Reasoning: It's true there are no physical ties here, but. They went out of their way to contract with a FL entity. They submitted to regulation by BK. Plus there's a FL choice-of-law clause.

Dicta: Stevens, dissenting: But the business was strictly in MI. This kind of superficial analysis tips the balance too far in the favor of franchisors.