Burger King Corp. v. Rudzewicz, 471 U.S. 462 (1985)
Burger King Corp. v.
Whether Florida courts may exercise specific personal jurisdiction over a nonresident franchisee based on a long-term franchise relationship, where the defendant purposefully engaged in substantial and continuing obligations with a Florida-based franchisor, consistent with due process under the Fourteenth Amendment.
To exercise specific personal jurisdiction consistent with due process, a defendant must have minimum contacts with the forum state such that the defendant has purposefully availed itself of the privilege of conducting activities there, giving it fair warning that it may be haled into court in that forum. A contract with a forum resident, standing alone, does not automatically establish jurisdiction; courts consider the parties' prior negotiations, contemplated future consequences, the terms of the contract, and the parties' actual course of dealing. Physical presence in the forum is not required; it is sufficient that the defendant purposefully directed activities toward the forum. Once purposeful availment and relatedness are established, the defendant must make a compelling showing that exercising jurisdiction would be unreasonable in light of factors such as the burden on the defendant, the forum state's interest, the plaintiff's interest in obtaining convenient and effective relief, the interstate judicial system's interest in efficient resolution, and the shared interests of the states in substantive social policies.
Yes. Florida's exercise of specific personal jurisdiction over the out-of-state franchisee was consistent with due process. The defendant purposefully established minimum contacts with Florida through a deliberate, long-term franchise relationship centered on Burger King's Miami headquarters, and the defendant did not show that jurisdiction in Florida would be so unreasonable as to violate fair play and substantial justice. The Supreme Court reversed the Eleventh Circuit and remanded for further proceedings consistent with its opinion.
Burger King operationalizes purposeful availment in the contract context and provides a framework for evaluating jurisdiction based on ongoing business relationships. It teaches that physical presence is not necessary for specific jurisdiction and that courts should holistically assess prior negotiations, contemplated consequences, contract terms, and course of dealing, with a choice-of-law clause as a meaningful, though not dispositive, signal. The case also clarifies that after minimum contacts are shown, the defendant bears the burden to make a compelling case that jurisdiction is unreasonable. For law students, the case is a staple for exam analysis on personal jurisdiction in contract and franchising scenarios and a guide for structuring interstate business relationships with jurisdictional consequences in mind.