Summary
The Eleventh Circuit affirmed the denial of motions to dismiss for lack of personal jurisdiction and to transfer venue in a negligence and breach-of-contract action arising from estate-planning services. The court held that Florida's long-arm statute reached alleged out-of-state negligence causing damage to a Florida estate and that the defendants had sufficient minimum contacts with Florida consistent with due process. The court also held that the district court did not abuse its discretion in denying transfer to Michigan.
Topics
Practice areas
Questions Presented
- Whether Florida's long-arm statute authorized personal jurisdiction over Michigan attorneys and an accountant whose allegedly negligent estate-planning services caused injury to a Florida estate.
- Whether exercising personal jurisdiction over the defendants complied with the Due Process Clause because the defendants had sufficient minimum contacts with Florida and jurisdiction was consistent with fair play and substantial justice.
- Whether the district court abused its discretion by denying a motion to transfer venue from Florida to Michigan under 28 U.S.C. section 1404(a).
Holdings
- Florida Statutes section 48.193(1)(b) reaches a foreign tortious act that causes injury in Florida. The complaint therefore sufficiently alleged a statutory basis for personal jurisdiction over the attorneys and accountant.
- The defendants had sufficient minimum contacts with Florida, and exercising specific personal jurisdiction comported with fair play and substantial justice.
- The district court did not abuse its discretion by denying the motion to transfer venue because the defendants did not clearly outweigh the plaintiff's choice of Florida forum with competing convenience and justice considerations.
Key quotations
“The determination of personal jurisdiction over a nonresident defendant requires a two-part analysis. First, we consider the jurisdictional question under the state long-arm statute. If there is a basis for the assertion of personal jurisdiction under the state statute, we next determine whether sufficient minimum contacts exist to satisfy the Due Process Clause of the Fourteenth Amendment so that "maintenance of the suit does not offend 'traditional notions of fair play and substantial justice.' " Only if both prongs of the analysis are satisfied may a federal or state court exercise personal jurisdiction over a nonresident defendant.” (¶ 13)
“the unilateral activity of those who claim some relationship with a nonresident defendant cannot satisfy the requirement of contact with the forum State ... it is essential in each case that there be some act by which the defendant purposefully avails itself of the privilege of conducting activities within the forum State, thus invoking the benefits and protections of its laws.” (¶ 25)
Factual background
The defendants, Michigan professionals, provided estate-planning and accounting services to Marvin Robinson after he moved to Florida. The attorneys drafted a will, codicil, and trust amendments identifying Robinson as a Florida resident and providing that Florida law would govern; the documents were mailed to and executed in Florida. The accountant reviewed the estate documents, prepared memoranda concerning tax consequences, and communicated with Robinson in Florida. After Robinson's death, the estate and trust incurred more than $850,000 in tax liability, and the estate was probated and administered in Broward County, Florida.
Procedural history
Robinson sued the defendants for negligence and breach of contract arising from allegedly defective estate-planning and tax advice. The United States District Court for the Southern District of Florida found personal jurisdiction under Florida Statutes section 48.193(1)(b) and the Due Process Clause, denied the request to transfer venue under 28 U.S.C. section 1404(a), and the defendants appealed. The Eleventh Circuit affirmed both rulings.