Summary
The Florida Fourth District Court of Appeal reversed a final judgment against Aramide Yusuf and remanded with instructions to dismiss the third-party complaint for lack of personal jurisdiction. The court held that the complaint did not allege that Yusuf committed a tortious act in Florida under Florida's long-arm statute, because the alleged conduct occurred in Texas between Texas residents. The court also rejected jurisdiction based on injury from a separate Florida transaction, vague conspiracy allegations, or the tracing of funds to Florida.
Holdings
- The complaint did not sufficiently allege that Yusuf committed a tortious act in Florida or that Ilunga's claims arose from tortious conduct in Florida. Because the alleged contribution and fraudulent-inducement conduct occurred in Texas, and mere injury in Florida or the Florida origin of the funds was insufficient, Florida lacked personal jurisdiction over Yusuf.
Questions Presented
- Whether Ilunga's third-party complaint sufficiently alleged that Yusuf committed a tortious act in Florida under section 48.193(1)(a)2., Florida Statutes, so as to establish specific personal jurisdiction.
Disposition
reversed_and_remanded
Cases Cited (8)
- International University of Health Sciences Ltd., Inc. v. Abeles, 299 So. 3d 405, 408 (Fla. 4th DCA 2020)(followed)
- Guarino v. Mandel, 327 So. 3d 853, 860-61 (Fla. 4th DCA 2021)(followed)
- Hunt v. Cornerstone Golf, Inc., 949 So. 2d 228, 230 (Fla. 4th DCA 2007)(followed)
- Kaminsky v. Hecht, 272 So. 3d 786, 788 (Fla. 4th DCA 2019)(followed)
- Metnick & Levy, P.A. v. Seuling, 123 So. 3d 639, 645 (Fla. 4th DCA 2013)(followed)
- Wendt v. Horowitz, 822 So. 2d 1252, 1260 (Fla. 2002)(followed)
- Reiss v. Ocean World, S.A., 11 So. 3d 404, 406-07 (Fla. 4th DCA 2009)(followed)
- NHB Advisors, Inc. v. Czyzyk, 95 So. 3d 444, 448 (Fla. 4th DCA 2012)(followed)
Cited In (0)
No citing cases on record yet.
Court Document
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