Heading: Burger King Corp v. Rudzewicz, 471 U.S. 462 (1985) p 68
Facts: D applied and got a Burger King franchise. The franchise was opened in Birmingham, Michigan. Burger King is a Miami corporation. Franchisees purchased $165,000 worth of equipment from Burger King in order to set up the restaurant. Even before final agreements were signed the parties began to disagree over site-development fees, design, rent, and whether the franchisees would be able to assign their liabilities to a corporation they had formed. Business was good for awhile but then started to decline. D could not make monthly payments to Miami. Headquarters sent notice of default and negotiations began. They were unsuccessful and Burger King ordered D to vacate the premises. They refused and continued to occupy and operate the facility as a Burger King restaurant.
Procedure: Burger King commenced action in the US District Court for the Souther District of Florida in May 1981. They alleged that D had breached their franchise obligations. Burger King sought damages, injunctive relief, and costs and attorney’s fees. D argued inter alia that Florida lacked jurisdiction. The District Court denied their motions. Trial court found Florida did have jurisdiction. Court of Appeals said they did not have jurisdiction.
Issue: Did Florida have jurisdiction over these Michigan residents and in light of the fact that Burger King’s claim did not arise within Florida?
Rule: When there are minimum contacts with a state, that state can have jurisdiction even if the minimum contacts did not mean physical presence in that state.
Holding: Because Rudzewicz established a substantial and continuing relationship with Burger King’s Miami headquarters, received fair notice from the contract documents and the course of dealing that he might be subject to suit in Florida, and has failed to demonstrate how jurisdiction in that forum would otherwise be fundamentally unfair, we conclude that the District Court’s exercise of jurisdiction pursuant to Florida Statute did not offend due process.
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