Burger King Corp. v. Rudzewicz 1985
Personal Jurisdiction CivPro – pg111 – 11/2/09
Parties: Π – Franchiser ∆ - Franchisee Procedural History: - Trial court found no personal jurisdiction - 11th circuit reverses (jurisdiction held) Facts: - π served as investment partner for a friend who wanted to manage a BK franchise - Application sent to Miami HQ - Preliminary agreement work at existing location - Purchased $165,000 of equipment - Disagreements over site-development fees, building design, computation of monthly rent, & assigning liabilities to a corporation ensued o Negotiated with regional and Miami office - Π obligated himself to >$1mil Legal Issue: Are there sufficient contacts with a state for personal jurisdiction where the primary engagement was around a contract? Holding: Yes. Personal jurisdiction can be found when the only contacts to the state are found in a contract. Reasoning: - Foreseeability not a “sufficient benchmark” - In Denckla the ∆ must purposefully avail in a place - In World-wide Volkswagon alternate concerns are listed which sometimes compensate for fewer minimum contacts - FLA ties: o No physical ties to Fla except for brief training o Grew out of K with substantial cxn w/ fla o Knew he was affiliating w/ fla o Franchise docs governed by Fla law - Holding is narrow to avoid concerns that case would reject any talismanic jurisdictional formula - Boilerplate not enough Disposition: Reversed Dissent/Concurrence: - Dissent – Stevens: o Principal contacts w/ mich office, Ø fla o Court relied on boilderplate language Creates potential for unfairness May severely impair Michigan witness from standing trial