personal jurisdiction defense in Florida

2022Minimum Contacts The second prong of the personal jurisdiction analysis requires us to determine whether the jurisdictional defendants “purposefully directed” their activities at a resident of the state “and the litigation results from alleged injuries that ‘arise out of or relate to’ those activities.” Burger King Corp. v. Rudzewicz, 471 U.S. 462, 472 (1985) (first quoting Keeton v. Hustler Magazine, Inc., 465 U.S. 770, 774 (1984); and then quoting Helicopteros Nacionales de Colombia, S.A. v. Hall, 466 U.S. 408, 414 (1984)).

2003See for example, Burger King, [ 471 U.S. at 472 n. 14, 105 S.Ct. 2174 ]: We have noted that, because the personal jurisdiction requirement is a waivable right, there are a "variety of legal arrangements" by which a litigant may give "express or implied consent to the personal jurisdiction of the court." (citation omitted).

2024The absence of that finding also compels reversal in this case.) (quoting Venetian Salami, 554 So. 2d at 500, 502 ) (additional citation omitted); Travel Ins.

2018Upon its conclusion, the trial court found that Appellants had satisfied the first prong of the personal jurisdiction test established in Venetian Salami v. Parthenais, 554 So. 2d 499, 502 (Fla. 1989), i.e., the Second Amended Complaint alleged sufficient jurisdictional facts (the alleged tortious acts) to bring the action within Florida’s long-arm statute.

2023In my view, the majority misplaces its reliance on the Supreme Court’s statement in Ford Motor Co. v. Montana Eighth Judicial District Court, 141 S. Ct. 1017, 1028 (2021), that “this Court has used this exact fact pattern (a resident-plaintiff sues a global car company, extensively serving the state market in a vehicle, for an in-state accident) as an illustration—even a paradigm example—of how specific jurisdiction works.” This statement was made in the context of the “arise out of or relate to” factor of the personal jurisdiction inquiry.

2023Unlike Mazda Japan, the defendant in Ford Motor Co. conceded purposeful availment as it had a “veritable truckload of contacts” with the forum states’ markets, and “[t]he only issue [in the case was] whether those contacts [were] related enough to the plaintiffs’ suits.” Id. at 1031 .

2022Minimum Contacts The second prong of the personal jurisdiction analysis requires us to determine whether the jurisdictional defendants “purposefully directed” their activities at a resident of the state “and the litigation results from alleged injuries that ‘arise out of or relate to’ those activities.” Burger King Corp. v. Rudzewicz, 471 U.S. 462, 472 (1985) (first quoting Keeton v. Hustler Magazine, Inc., 465 U.S. 770, 774 (1984); and then quoting Helicopteros Nacionales de Colombia, S.A. v. Hall, 466 U.S. 408, 414 (1984)).

2022Minimum Contacts The second prong of the personal jurisdiction analysis requires us to determine whether the jurisdictional defendants “purposefully directed” their activities at a resident of the state “and the litigation results from alleged injuries that ‘arise out of or relate to’ those activities.” Burger King Corp. v. Rudzewicz, 471 U.S. 462, 472 (1985) (first quoting Keeton v. Hustler Magazine, Inc., 465 U.S. 770, 774 (1984); and then quoting Helicopteros Nacionales de Colombia, S.A. v. Hall, 466 U.S. 408, 414 (1984)).

2021See Babcock v. Whatmore, 707 So. 2d 702, 704 (Fla. 1998) (holding “a defendant waives a challenge to personal jurisdiction by seeking affirmative relief—such requests are logically inconsistent with an initial defense of lack of jurisdiction.”) 6

2019See, e.g., Fabara v. GoFit, LLC, 308 F.R.D. 380, 400 (D.N.M. 2015) (construing a defendant's "denial of [a] personal-jurisdiction allegation as effectively asserting a personal-jurisdiction defense"); McDermott v. FedEx Ground Sys., Inc., 520 F. Supp. 2d 254, 257 (D.

2019See, e.g., Fabara v. GoFit, LLC, 308 F.R.D. 380, 400 (D.N.M. 2015) (construing a defendant's "denial of [a] personal-jurisdiction allegation as effectively asserting a personal-jurisdiction defense"); McDermott v. FedEx Ground Sys., Inc., 520 F. Supp. 2d 254, 257 (D.

2008“Proceedings supplementary are post-judgment proceedings that permit a creditor to effectuate a judgment lien already existing; they are not independent causes of action.” Zureikat v. Shaibani, 944 So.2d 1019, 1022 (Fla. 5th DCA 2006); Schwartz v. Capital City First Nat’l Bank, 365 So.2d 181, 183 (Fla. 1st DCA 1978) (holding that proceedings supplementary to judgment are a continuation of the underlying proceedings).

2008“Proceedings supplementary are post-judgment proceedings that permit a creditor to effectuate a judgment lien already existing; they are not independent causes of action.” Zureikat v. Shaibani, 944 So.2d 1019, 1022 (Fla. 5th DCA 2006); Schwartz v. Capital City First Nat’l Bank, 365 So.2d 181, 183 (Fla. 1st DCA 1978) (holding that proceedings supplementary to judgment are a continuation of the underlying proceedings).