Thursday, February 7, 2013

Burger King Corp. v. Rudzewicz case brief

Burger King Corp. v. Rudzewicz
471 U.S. 462

SYNOPSIS: On a writ of certiorari, appellant franchisor sought review of the judgment of the United States Court of Appeals for the Eleventh Circuit, which found that the State of Florida could not exercise jurisdiction over appellee franchisee under Fla. Stat. ch. 48.193(1)(g) (Supp. 1984), in an action for breach of contract.

FACTS: Appellant brought suit against appellee for breach of contract in the Florida courts. The court of appeals reversed the holding of the lower court that Fla. Stat. ch. 48.193(1)(g) (Supp. 1984) granted the Florida courts personal jurisdiction over the appellee.

 On review, the Supreme Court determined that a party that avails themselves of the protections and benefits of the law of a forum state is subject to personal jurisdiction of that state.

The court found that the appellees had entered into a contract and established a substantial and continuing relationship with the appellant, a Florida resident. The court further found that the appellee had fair notice that he might be subject to suit in Florida. The court further found that the exercise of jurisdiction would not offend due process and reversed the holding of the court of appeals and remanded for further proceedings.

-Where a forum seeks to assert specific jurisdiction over an out-of-state defendant who has not consented to suit there, the fair warning requirement is satisfied if the defendant has purposefully directed his activities at residents of the forum, and the litigation results from alleged injuries that arise out of or relate to those activities.
-A State generally has a manifest interest in providing its residents with a convenient forum for redressing injuries inflicted by out-of-state actors. Moreover, where individuals purposefully derive benefit from their interstate activities it may well be unfair to allow them to escape having to account in other States for consequences that arise proximately from such activities.
-The Due Process Clause may not readily be wielded as a territorial shield to avoid interstate obligations that have been voluntarily assumed.

CONCLUSION: Judgment of the court of appeals finding the Florida courts could not exercise jurisdiction over appellee was reversed because the exercise of jurisdiction by the Florida courts was not a violation of due process.

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