section 48.193(1) long arm jurisdiction in Florida

2026See Venetian Salami, 554 So. 2d at 502 ; Ellis, 397 So. 3d at 766.

2026See Venetian Salami, 554 So. 2d at 502 ; Ellis, 397 So. 3d at 766.

2026As we held in Straub, Seaman & Allen, P.C. v. Ellis, 397 So. 3d 763 , 766 (Fla. 2d DCA 2024): "Before a Florida court can exercise personal jurisdiction over a nonresident defendant, a two-stage inquiry is conducted." [Kountze v. Kountze, 996 So. 2d 246, 251 (Fla. 2d DCA 2008).] In the first stage, a trial court must determine whether there are sufficient jurisdictional facts to support long-arm jurisdiction pursuant to section 48.193, Florida Statutes (2021).

2026As we held in Straub, Seaman & Allen, P.C. v. Ellis, 397 So. 3d 763 , 766 (Fla. 2d DCA 2024): "Before a Florida court can exercise personal jurisdiction over a nonresident defendant, a two-stage inquiry is conducted." [Kountze v. Kountze, 996 So. 2d 246, 251 (Fla. 2d DCA 2008).] In the first stage, a trial court must determine whether there are sufficient jurisdictional facts to support long-arm jurisdiction pursuant to section 48.193, Florida Statutes (2021).

2026As we held in Straub, Seaman & Allen, P.C. v. Ellis, 397 So. 3d 763 , 766 (Fla. 2d DCA 2024): "Before a Florida court can exercise personal jurisdiction over a nonresident defendant, a two-stage inquiry is conducted." [Kountze v. Kountze, 996 So. 2d 246, 251 (Fla. 2d DCA 2008).] In the first stage, a trial court must determine whether there are sufficient jurisdictional facts to support long-arm jurisdiction pursuant to section 48.193, Florida Statutes (2021).

2026As we held in Straub, Seaman & Allen, P.C. v. Ellis, 397 So. 3d 763 , 766 (Fla. 2d DCA 2024): "Before a Florida court can exercise personal jurisdiction over a nonresident defendant, a two-stage inquiry is conducted." [Kountze v. Kountze, 996 So. 2d 246, 251 (Fla. 2d DCA 2008).] In the first stage, a trial court must determine whether there are sufficient jurisdictional facts to support long-arm jurisdiction pursuant to section 48.193, Florida Statutes (2021).

2024Caliva failed to substantiate its allegations of intentional tortious conduct on the part 4 This analysis dovetails with Caliva’s other alleged ground for long-arm jurisdiction under section 48.193(1)(a)2 for committing a tortious act in Florida. 5 Unlike the affidavit in Acqadro v. Bergeron, 851 So. 2d 665, 672 (Fla. 2003), Harrison’s affidavit provided more than a mere legal conclusion that the conduct at issue was not actionable. 13 of Harrison, focusing instead on attempting to establish jurisdiction based on Harrison’s extensive business contacts with Florida.

2007Horowitz, 822 So.2d at 1258 ( citing Carida v. Holy Cross Hosp., 424 So.2d 849 (Fla. 4th DCA 1982)(slanderous telephone calls into state can support a finding of tortuous act committed in Florida), overruled on other grounds, Doe v. Thompson, 620 So.2d at 1004 ; Silver v. Levinson, 648 So.2d 240 (Fla. 4th DCA 1994)(mailing of defamatory letter into Florida); Achievers Unlimited, Inc. v. Nutri Herb, Inc., 710 So.2d 716 (Fla. 4th DCA 1998)(defamatory statements over telephone to Florida residents by nonresident); Acquadro v. Bergeron, 778 So.2d 1034 (Fla. 4th DCA 2001)(telephone conversations ma

2010Casita, L.P. v. Maplewood Equity Partners, L.P., 960 So.2d 854, 857 (Fla. 3d DCA 2007) (“A telephonic, electronic, or written communication is deemed ‘published’ in Florida, subjecting the publisher to long-arm jurisdiction under section 48.193(1)(b) of the Florida Statutes if the communication was made into this state by a person outside the state, even if that person has no other contacts with the state.” (citing Wendt, 822 So.2d at 1258 )).

2007Horowitz, 822 So.2d at 1258 ( citing Carida v. Holy Cross Hosp., 424 So.2d 849 (Fla. 4th DCA 1982)(slanderous telephone calls into state can support a finding of tortuous act committed in Florida), overruled on other grounds, Doe v. Thompson, 620 So.2d at 1004 ; Silver v. Levinson, 648 So.2d 240 (Fla. 4th DCA 1994)(mailing of defamatory letter into Florida); Achievers Unlimited, Inc. v. Nutri Herb, Inc., 710 So.2d 716 (Fla. 4th DCA 1998)(defamatory statements over telephone to Florida residents by nonresident); Acquadro v. Bergeron, 778 So.2d 1034 (Fla. 4th DCA 2001)(telephone conversations ma

2024“Long-arm jurisdiction under section 48.193 may be established in one of two ways: ‘general’ jurisdiction or ‘specific’ jurisdiction.” Banco de los Trabajadores v. Cortez Moreno, 237 So. 3d 1127, 1132 (Fla. 3d DCA 2018).

2019See Becker v. Hooshmand, 841 So. 2d 561, 562 (Fla. 4th DCA 2003).

2018Rautenberg v. Falz, 193 So. 3d 924, 928 (Fla. 2d DCA 2016).

2015Corp. of Palm Beach v. WBC Constr., L.L.C., 925 So.2d 1156, 1160 (Fla. 4th DCA 2006). *828 By each count of their complaint, Ms. Knox and her daughter sought to secure jurisdiction over the Barbados defendants under section 48.193, which in pertinent part provides: A person, whether or not a citizen or resident of this state, who personally or through an agent does any of the acts enumerated in this subsection thereby submits himself or herself ... to the jurisdiction of the courts of this state for any cause of action arising from any of the following acts: [[Image here]] 2.

2011Humane Soc’y, Inc., 941 So.2d 540, 545 (Fla. 1st DCA 2006) (‘"When ... the question whether a Florida court has ‘general’ jurisdiction over the person of a nonresident defendant arises under section 48.193(2), these separate inquiries (long-arm statute and minimum contacts) merge.”); Woods, 739 So.2d at 620 (“Because section 48.193(2) requires [the] high threshold [of substantial, continuous, and systematic business contacts], if the defendant’s activities meet the requirements of section 48.193(2), minimum contacts is also satisfied.”); Kertesz v. Net Transactions, Ltd., 635 F.Supp.2d 1339, 1

2011Humane Soc’y, Inc., 941 So.2d 540, 545 (Fla. 1st DCA 2006) (‘"When ... the question whether a Florida court has ‘general’ jurisdiction over the person of a nonresident defendant arises under section 48.193(2), these separate inquiries (long-arm statute and minimum contacts) merge.”); Woods, 739 So.2d at 620 (“Because section 48.193(2) requires [the] high threshold [of substantial, continuous, and systematic business contacts], if the defendant’s activities meet the requirements of section 48.193(2), minimum contacts is also satisfied.”); Kertesz v. Net Transactions, Ltd., 635 F.Supp.2d 1339, 1

2011Humane Soc’y, Inc., 941 So.2d 540, 545 (Fla. 1st DCA 2006) (‘"When ... the question whether a Florida court has ‘general’ jurisdiction over the person of a nonresident defendant arises under section 48.193(2), these separate inquiries (long-arm statute and minimum contacts) merge.”); Woods, 739 So.2d at 620 (“Because section 48.193(2) requires [the] high threshold [of substantial, continuous, and systematic business contacts], if the defendant’s activities meet the requirements of section 48.193(2), minimum contacts is also satisfied.”); Kertesz v. Net Transactions, Ltd., 635 F.Supp.2d 1339, 1

2010We conclude that Golant’s allegations are sufficient to satisfy both prongs of the Venetian Salami test with respect to section 48.193(l)(a), which confers long arm jurisdiction over a defendant for actions arising from “[Operating, conducting, engaging in, or carrying on a business or business venture in this state or having an office or agency in this state.” To invoke long arm jurisdiction under section 48.193(l)(a), the activities of the corporation “must be considered collectively and show a general course of business activity in the State for pecuniary benefit.” Dinsmore v. Martin Blumen

2010We conclude that Golant’s allegations are sufficient to satisfy both prongs of the Venetian Salami test with respect to section 48.193(l)(a), which confers long arm jurisdiction over a defendant for actions arising from “[Operating, conducting, engaging in, or carrying on a business or business venture in this state or having an office or agency in this state.” To invoke long arm jurisdiction under section 48.193(l)(a), the activities of the corporation “must be considered collectively and show a general course of business activity in the State for pecuniary benefit.” Dinsmore v. Martin Blumen

2010Casita, L.P. v. Maplewood Equity Partners, L.P., 960 So.2d 854, 857 (Fla. 3d DCA 2007) (“A telephonic, electronic, or written communication is deemed ‘published’ in Florida, subjecting the publisher to long-arm jurisdiction under section 48.193(1)(b) of the Florida Statutes if the communication was made into this state by a person outside the state, even if that person has no other contacts with the state.” (citing Wendt, 822 So.2d at 1258 )).

2008See Hilltopper Holding Corp. v. Estate of Cutchin, 955 So.2d 598, 601 (Fla. 2d DCA 2007) (citing Venetian Salami, 554 So.2d at 502 ).

2003The trial court granted the motion, concluding that once the defendant filed an affidavit contesting personal jurisdiction, the burden of proof shifted to [the plaintiff] to demonstrate by a preponderance of the evidence that [the defendant] had in fact committed the tort of civil conspiracy *368 within Florida and was therefore subject to this Court's long-arm jurisdiction pursuant to Section 48.193(1)(b)[.] Id. at 359 (emphasis supplied).

2003Section 48.193(1)(b) provides long-arm jurisdiction over a non-resident who commits a tortious act within this state. "[A] tort claim `is deemed to have accrued where the last event necessary to make the defendant liable for the tort took place.' As to the tort of conversion, that act constitutes the exercise of wrongful dominion and control over the property to the detriment of the rights of its actual owner." Envases Venezolanos, S.A. v. Collazo, 559 So.2d 651, 652 (Fla. 3d DCA 1990)(quoting Tucker v. Fianson, 484 So.2d 1370, 1371 (Fla. 3d DCA), review denied, 494 So.2d 1153 (Fla.1986)) (cit

2003See Stomar, Inc. v. Lucky Seven Riverboat Co., L.L.C., 821 So.2d 1183 (Fla. 4th DCA 2002); Indus.

2002See Garrett v. Garrett, 652 So.2d 378 (Fla. 1st DCA 1994).

2002See Wrenn v. McDonnell, 671 So.2d 884 (Fla. 5th DCA 1996).