Plaintiff brought suit in Florida for Defendant’s breach of their franchise agreement. Defendant argued that Florida lacked personal jurisdiction.
A nonresident defendant may be subject to personal jurisdiction under the Due Process Clause if they purposefully direct their activities toward the forum state, sufficiently creating minimum contacts with the state.
Rudzewicz (Defendant) and MacShara jointly applied for a Burger King franchise in their home state of Michigan. Burger King Corporation (Plaintiff), headquartered in Florida, approved the 20-year franchise relationship after a long negotiation process between the parties. In this contract, Defendant obligated himself to payments of over $1 million to the Plaintiff’s headquarters in Florida and agreed to the terms of contract being governed by Florida law. When Defendant and MacShara fell behind on payments, Plaintiff brought a suit under Florida’s long-arm statute for breach of the franchise agreement. Defendant argued that the suit could not be brought in Florida for lack of personal jurisdiction.
Does Florida’s long-arm statute violate due process by permitting personal jurisdiction over nonresident defendants who breach a contract?
No, based on the facts of this case Florida’s long arm statute does not violate due process. The decision of the Appeals Court is reversed and remanded.
Justice Stevens argued that it was unfair to require a franchisee to defend themselves in the forum chosen by the franchisor. Based on the facts of the case, Justice Stevens argued that Defendant had more business connections with Michigan and the Court should not have relied so heavily on the boilerplate language of the contract.
The Court concluded that Florida had personal jurisdiction over Defendant because Defendant purposefully established a substantial and continuing relationship with the Plaintiff in Florida. Additionally, Defendant was given reasonable notice of litigation in Florida in the contract he signed.