Burger King v Rudzewicz case brief PDF

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Burger King v. Rudzewicz 471 U.S. 462, 105 S.Ct. 2174, 85 L.Ed.2d 528 US District Court for Southern Florida Court of Appeals Supreme Court of the U.S. Facts:

Rudzewicz and MacShara jointly entered into a Franchise Contract with Burger King to open a location in Birmingham, Michigan. Contracts signed by Franchisees with Burger King agree to hold the governing contracts in Miami and are subject to Florida Law. Furthermore, all payments agreed upon as well as relevant notices are paid to and sent to the Miami headquarters. Franchisees fell far behind in monies owed, and as such, Burger King terminated the Franchise agreement and ordered the defandants to vacate the business. Defendants refused and continued to operate their business in Michigan. Suit was brought against Defendants in the US District Court for the Southern District of Florida for a breach of contract, monies owed and a tortuous infringement of trademark rights. Defendants argued over jurisdiction for case brought in Florida.

Issues:

Minimum Contacts to assert state jurisdiction in Florida (Diversity and Federal Law Juridiction for Federal Court Suit). Whether or not there the lack of a contractual waiver of objection to jurisdiction matters. Foreseeability of Liability. Did the Defendants purposefully establish “minimum contacts” within the Forum State of Florida?

Rule of Law:

Florida’s Long Arm Statute which allows extension of jurisdiction to any person whether or not a citizen or resident of the state who breaches a contract within the state.

Holding:

District Court held that there does not need to be a physical presence within the state of Florida to maintain Minimum Contacts for the basis of personal Jurisdiction. As there was no waiver of objection for jurisdiction on the contracts signed, that the Defendants can indeed to held liable in the State of Florida. Forseeability of liability in light of interest considerations. Prima Facia: considerations were to see whether personal jurisdiction fulfills fair substantial justice. Jurisdiction CAN NOT be avoided just because there was no physical presence within the State of Florida. Court of Appeals ruled on choice-of-law provisions in the entering of a 20year agreement. Supreme Court Disagreed and sent the case back for further proceedings.

Reasoning:

It was decided that it may be unfair to allow a non-resident party to escape having to account for activities that arise in another state. Due Process may not be used as a shield to avoid such interstate obligations.

There was also no waiver of obligation to in personam jurisdiction within the contracts signed. Analysis/Opinions: This case seemed complicated on its face. The State of Michigan after this also adopted franchise statutes as law making it illegal for arbitration or litigation against business within the state to happen outside the state. In My opinion, as Burger King operates not only everywhere within the US, but also others countries around the world, it would be a greater burden on Burger King as a corporation to recover damages on contract breaches if it needs to travel and not have the ability to bring suit where the contracts were signed out of, which is the State of Florida – pursuant to Diversity Jurisdiction....