Facts
- A Canadian meat-processing company allegedly retained a Florida-based collections business operator to assess collectability and collection methods for a large delinquent account.
- The plaintiff alleged the defendant contacted him in Florida, agreed to reimburse expenses, and agreed that payment would be made to him at his Florida place of business.
- The plaintiff alleged he performed the services but the defendant refused to pay.
- The defendant submitted affidavits asserting it did not do business in Florida, the relevant dealings occurred outside Florida, and no agreement required payment in Florida.
- The parties’ affidavits directly conflicted on key jurisdictional facts, including where the agreement was reached, where performance and payment were required, and the extent of the defendant’s Florida contacts.
- The trial court dismissed for lack of personal jurisdiction, concluding the plaintiff failed to establish sufficient minimum contacts.
- The district court of appeal reversed, treating satisfaction of the long-arm statute as sufficient without a separate minimum-contacts analysis.
Issues
- After a plaintiff pleads a basis for jurisdiction under Florida’s long-arm statute, must a court also independently determine whether exercising jurisdiction satisfies due process (minimum contacts)?
- When the parties submit conflicting affidavits on material jurisdictional facts, must the trial court conduct a limited evidentiary hearing to resolve the dispute?
Decision
- The Florida Supreme Court quashed the district court of appeal’s decision.
- The Court held Florida courts must apply a two-step inquiry: (1) statutory authorization under the long-arm statute and (2) constitutional due process minimum contacts.
- The Court held that when jurisdictional affidavits are irreconcilably in conflict on material facts, the trial court must hold a limited evidentiary hearing to resolve those facts.
- The case was remanded for further proceedings consistent with these requirements.
Legal Principles
- Personal jurisdiction over a nonresident requires both: (1) allegations and proof bringing the claim within Florida’s long-arm statute, and (2) sufficient minimum contacts so jurisdiction accords with due process.
- Statutory reach under the long-arm statute does not eliminate the separate constitutional inquiry; due process requires contacts such that the defendant should reasonably anticipate being sued in Florida.
- Minimum-contacts analysis focuses on the defendant’s purposeful conduct connected to Florida, including where negotiations occurred and where contractual obligations (such as payment) were to be performed.
- Burden shifting on a motion to quash service:
- The plaintiff must plead a statutory basis for jurisdiction.
- If the defendant’s affidavit fully refutes jurisdictional allegations, the burden shifts back to the plaintiff to produce evidence supporting jurisdiction.
- If material facts in the affidavits cannot be reconciled, the court must hold a limited evidentiary hearing to determine jurisdiction.
Conclusion
The court held that Florida long-arm jurisdiction requires both a statutory basis and a separate due-process minimum-contacts showing, and that irreconcilable affidavit disputes over jurisdictional facts must be resolved through a limited evidentiary hearing.