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Burger King Corp. v. Rudzewicz

Supreme Court of the United States · 1985 · Civil Procedure

Civil Procedurepersonal jurisdictionminimum contactspurposeful availmentcontractpersonal jurisdictiondue processfundamental fairness

Facts

Rudzewicz was a Burger King franchisee who operated only in Michigan. He maintained no place of business, employees, or business license in Florida, and he sold all of his products in Michigan while paying taxes there. During the parties' relationship, his principal contacts were with Burger King's Michigan office, which handled the negotiations, supervised the contract, and provided the relevant services. The franchise documents contained standard form language pointing to Florida, but Rudzewicz allegedly had no direct negotiations with anyone in Miami, may never have visited Florida, and signed nonnegotiable forms in a relationship marked by superior bargaining power on Burger King's side.

Issue

Whether due process permits Florida courts to exercise personal jurisdiction over a Michigan Burger King franchisee when his business operations and principal dealings were centered in Michigan and his connection to Florida rested largely on standard form contractual language and the franchisor's distant headquarters.

Rule

Jurisdiction offends due process when the circumstances leave a defendant without reasonable notice of possible litigation in the forum and financially unprepared for the burdens of distant litigation, especially where the defendant's actual dealings are localized elsewhere and the asserted forum connection rests primarily on boilerplate contractual terms imposed in a franchise relationship.

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One of 10 multiple-choice questions for this case. Pick an answer to see why.

Maya Patel bought a franchise to operate a single frozen-yogurt shop in Columbus, Ohio from Suncrest Treats Group, whose headquarters are in Arizona. Every interview, phone call, site visit, and training session was handled by Suncrest’s Ohio regional office, and Maya never communicated with anyone in Arizona before signing a standard-form agreement that included an Arizona choice-of-law clause. When the relationship soured, Suncrest sued Maya in Arizona state court.

Under the opinion’s reasoning, is Arizona’s exercise of personal jurisdiction over Maya most consistent with due process?

Explanation. The opinion focuses on fair notice and fundamental fairness. Where the franchisee’s business is entirely local and the actual negotiations and supervision were conducted through the home-state regional office, the franchisee would reasonably expect litigation, if anywhere, in that state rather than at distant headquarters. The opinion rejects relying primarily on standard boilerplate contractual language to create forum contacts. (Derived from Burger King Corp. v. Rudzewicz (1985).)