Document Sample
					CIV PRO
BURGER KING V. RUDZEWICZ, Supreme Court of US, 1985. 471 US 462, 105 S.Ct. 2174, 85 L.Ed.2d 528. History: BK brought diversity action in Federal Dist. Ct. in FL b/c franchisees had breached their franchise obligations and BK was seeking damages and injunctive relief; Court held franchisees were subject to personal jurisdiction under FL long-arm statute; Court of Appeals reversed holding jurisdiction in this case would offend due process; Appeal from 11th Circuit US Ct. of Appeals Facts: BK is FL corporation whose main offices are in FL; franchises are licensed to use trademark, etc. for 20 years; day-to-day monitoring is done through district offices, who then report to headquarters in Miami; Contracts provide franchise relationship is est. in Miami and governed by FL law; Rudzewicz (MI) franchised a BK and it went under Issue(s): Whether FL, under 14th Amendment, can exercise jurisdiction over Rudzewicz for BK case. Holding: Exercise of jurisdiction did not offend 14th Amendment Analysis: Foreseeability that is critical to due process analysis is if defendant’s conduct and connection w/forum state are such that he should reasonably anticipate being dragged into court there; Prior negotiations and contemplated future consequences determine whether defendant purposefully established minimum contacts w/forum state; Rudzewicz deliberately reached out beyond MI and negotiated w/FL corporation a long-term franchise and the benefits that would derive from affiliation w/nationwide organization Contract documents say BK’s operations are conducted and supervised in FL; Rudzewicz also received fair notice from contract papers