## Facts

- Glovegold Shipping, Ltd. (Glovegold), a Maltese corporation, owned the cargo vessel *Anthenor Express*.
- Glovegold obtained hull-and-machinery marine insurance for the vessel from Sveriges Angfartygs Assurans Forening, also known as The Swedish Club (TSC), a Swedish marine insurer.
- At the time the insurance was placed, the vessel was berthed in Florida and regularly ran trade routes in and out of Florida ports.
- TSC advertised that it maintained a worldwide claims network, including local agents available to respond to claims, and that network included agents located in Florida.
- The vessel later suffered catastrophic hull-and-machinery damage while in Florida waters and was towed to a Florida port for repairs.
- Glovegold submitted a claim to TSC for the loss and repair costs under the policy.
- TSC dispatched local Florida agents to investigate the loss and assess the claim.
- TSC ultimately denied coverage.
- Glovegold sued TSC in Florida circuit court for breach of its insurance obligations.
- TSC moved to dismiss for lack of personal jurisdiction, arguing it lacked sufficient Florida contacts and that the insurance contract’s foreign character defeated Florida jurisdiction.
- The trial court dismissed the case for lack of personal jurisdiction, and Glovegold appealed.

## Issues

1. Whether Florida courts may exercise specific personal jurisdiction over a foreign marine insurer that insured a vessel berthed in Florida and regularly calling at Florida ports, when the insured loss occurred in Florida waters and the insurer denied coverage.

## Decision

- The First District Court of Appeal reversed the dismissal and remanded.
- The court concluded Florida’s long-arm statute was satisfied because the dispute arose from TSC’s insurance of a risk tied to Florida and a loss occurring in Florida waters.
- The court further held that exercising jurisdiction comported with due process because TSC could reasonably anticipate being sued in Florida based on its relationship to the insured vessel’s Florida operations and the Florida-centered loss and investigation.

## Legal Principles

- Florida courts apply a two-step analysis for personal jurisdiction: (1) statutory authorization under the long-arm statute and (2) constitutional due process (minimum contacts and fairness).
- Specific jurisdiction over a foreign insurer may exist when the insurer insures a risk with meaningful Florida connections and the cause of action arises from a Florida loss for which coverage is denied.
- For due process, a foreign insurer’s minimum contacts may be shown when it knowingly insures a vessel that is based in Florida or regularly operates through Florida ports and the disputed claim arises from a casualty in Florida waters.
- Claim investigation conducted through in-state agents in connection with the Florida loss supports the connection among the defendant, Florida, and the coverage dispute.

## Conclusion

The appellate court held that Florida could exercise specific personal jurisdiction over The Swedish Club where the insured vessel had strong Florida ties, the casualty occurred in Florida waters, and the insurer investigated in Florida before denying coverage; the trial court’s jurisdictional dismissal was reversed and the case was returned for further proceedings.


Glovegold Shipping, Ltd. v. Sveriges Angfartygs Assurans Forening, 791 So. 2d 4 (2000)