Hampton Island Preservation, LLC v. Club & Community Corporation

Summary

The Florida Fourth District Court of Appeal considered whether Florida courts had personal jurisdiction over a Georgia limited liability company in a contract-related damages action. The court held that the allegations satisfied Florida's long-arm statute, but the plaintiff failed to establish constitutionally sufficient minimum contacts after the defendant contested jurisdiction by affidavit. The court reversed and remanded with directions to dismiss the second amended complaint for lack of personal jurisdiction.

Holdings

1. CCC alleged sufficient unrebutted facts to satisfy the first prong of Florida's personal-jurisdiction inquiry because the contract was allegedly made with a Florida resident and required payment in Florida.
2. CCC failed to establish sufficient minimum contacts to satisfy the constitutional due-process prong of personal jurisdiction because, after Hampton Island contested jurisdiction by affidavit, CCC submitted no opposing affidavit or other evidence establishing minimum contacts.
3. A forum-selection clause designating Florida cannot operate as the sole basis for Florida to exercise personal jurisdiction over an objecting nonresident defendant, particularly where the clause appeared in an unsigned agreement.

Questions Presented

1. Whether Florida's long-arm statute supplied a basis for personal jurisdiction over Hampton Island based on the alleged contractual requirement that payments be made in Florida.
2. Whether Hampton Island had sufficient minimum contacts with Florida to satisfy constitutional due process.
3. Whether the unsigned forum-selection clause, standing alone, could establish personal jurisdiction over an objecting nonresident defendant.

Disposition

reversed_and_remanded