Narrative Opinion Summary
The appellate court affirmed the trial court's decision regarding a motion to dismiss based on lack of personal jurisdiction. It emphasized that while appellate review of such orders is de novo, when the trial court's decision relies on live testimony, the appellate court defers to the trial court’s factual determinations. The court cited precedent indicating that an appellate court reviews findings of fact for competent, substantial evidence. It also addressed the due process requirement of minimum contacts, clarifying that merely entering into a contract with a non-resident or requiring payment in Florida does not meet this standard. Specifically, in the context of a breach of contract action, the court ruled that the defendant's failure to pay a debt in Florida and a choice-of-law provision requiring Florida law were insufficient to establish long-arm jurisdiction over the non-resident defendant.
Legal Issues Addressed
Due Process Requirement of Minimum Contactssubscribe to see similar legal issues
Application: The court clarified that entering into a contract with a non-resident or requiring payment in Florida does not satisfy the minimum contacts standard necessary for personal jurisdiction under due process.
Reasoning: It also addressed the due process requirement of minimum contacts, clarifying that merely entering into a contract with a non-resident or requiring payment in Florida does not meet this standard.
Long-Arm Jurisdiction in Breach of Contractsubscribe to see similar legal issues
Application: The court ruled that a choice-of-law provision requiring Florida law and a failure to pay a debt in Florida were insufficient to establish long-arm jurisdiction over a non-resident defendant in a breach of contract action.
Reasoning: Specifically, in the context of a breach of contract action, the court ruled that the defendant's failure to pay a debt in Florida and a choice-of-law provision requiring Florida law were insufficient to establish long-arm jurisdiction over the non-resident defendant.
Review of Findings of Factsubscribe to see similar legal issues
Application: Appellate courts review findings of fact for competent, substantial evidence, which informs their review of jurisdictional decisions.
Reasoning: The court cited precedent indicating that an appellate court reviews findings of fact for competent, substantial evidence.
Standard of Review for Personal Jurisdictionsubscribe to see similar legal issues
Application: The appellate court reviews orders dismissing a case for lack of personal jurisdiction de novo, but defers to the trial court's factual determinations when those are based on live testimony.
Reasoning: It emphasized that while appellate review of such orders is de novo, when the trial court's decision relies on live testimony, the appellate court defers to the trial court’s factual determinations.