Facts
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Camp Illahee Investors, Inc. owned and operated a girls’ summer camp located in North Carolina; the corporation and individual owners were based in North Carolina.
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Florida parents sued in Florida on behalf of their minor daughters, who attended the camp in North Carolina in 2001.
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The complaint alleged two categories of tortious conduct occurring in North Carolina during camp attendance:
- An anonymous child-abuse report led North Carolina social services to interview the children; plaintiffs alleged defendants had a duty to notify the parents before such interviews.
- A junior counselor allegedly battered one child and caused physical and mental harm.
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To support Florida personal jurisdiction, plaintiffs pointed to Florida-related activity by the camp:
- The camp maintained a website that included information about fall reunions and video shows.
- One owner traveled to Florida about one week per year to attend reunions and host promotional video shows in private homes of camper families.
- The camp had no Florida offices and no Florida employees, though some seasonal staff were Florida residents; it did not advertise in Florida via newspapers, radio, or television.
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The trial court denied the camp’s motion to dismiss for lack of personal jurisdiction.
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The camp took an interlocutory appeal challenging only personal jurisdiction.
Issues
- Whether the camp’s Florida reunions, promotional video shows, and website posting constituted “carrying on a business” or engaging in “business ventures” in Florida under Fla. Stat. § 48.193(1)(a).
- Whether, assuming qualifying Florida business activity, the plaintiffs’ tort claims “arose from” that activity as required by the statute’s connexity requirement.
Decision
- The appellate court reversed the nonfinal order denying dismissal for lack of personal jurisdiction.
- The court held the long-arm statute was not satisfied because the connexity requirement was not met.
- The alleged injuries arose from events in North Carolina and did not arise from, or substantially relate to, the camp’s limited Florida promotional activity.
- Because no statutory basis for jurisdiction was established, the court did not conduct an extended due process minimum-contacts analysis.
- The case was remanded with directions consistent with dismissal for lack of personal jurisdiction over the camp.
Legal Principles
- Florida courts apply a two-step jurisdiction analysis: (1) whether the long-arm statute authorizes jurisdiction, and (2) if so, whether due process is satisfied.
- Under Fla. Stat. § 48.193(1)(a), even if a defendant carries on business in Florida, the plaintiff’s cause of action must “arise from” that Florida activity (connexity requirement).
- Connexity requires a causal or at least substantial connection between the Florida activity and the claim; Florida-related marketing or promotional contacts alone do not confer jurisdiction over claims based on out-of-state torts.
Conclusion
Florida lacked personal jurisdiction because the plaintiffs’ claims concerned alleged torts occurring entirely in North Carolina and did not arise from the camp’s limited, annual Florida promotional reunions and related website information, so the long-arm statute’s connexity requirement was not met.