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Boca Research, Inc. v. Kroll Associates, Inc.

Citations: 677 So. 2d 419; 1996 Fla. App. LEXIS 8243; 1996 WL 441529Docket: No. 96-416

Court: District Court of Appeal of Florida; August 7, 1996; Florida; State Appellate Court

Narrative Opinion Summary

Boca Research, Inc. appealed a trial court order denying its motion to transfer venue from Dade County to Palm Beach County in a breach of contract case initiated by Kroll Associates, Inc., a foreign corporation with offices in Dade County. Kroll alleged that Boca Research, a Florida corporation with an office in Palm Beach County, failed to pay for services rendered under their agreement. Kroll filed the lawsuit in Dade County, asserting that the cause of action accrued there, as the payment location was not specified in their agreement and generally defaults to the creditor's location. Citing Florida Statutes § 47.051 and relevant case law, the court determined that the cause of action accrued in Dade County because the debtor must seek payment from the creditor, implying that payment was to be made at Kroll's location. Consequently, the trial court's denial of Boca Research's motion to transfer venue was affirmed.

Legal Issues Addressed

Affirmation of Trial Court's Venue Decision

Application: The trial court's decision to deny the motion to transfer venue was affirmed based on the determination that the cause of action accrued in Dade County, aligning with statutory and case law precedents.

Reasoning: Consequently, the trial court's denial of Boca Research's motion to transfer venue was affirmed.

Default Payment Location in Contract Disputes

Application: In the absence of a specified payment location in the contract, the court held that the default location is the creditor's place of business, which in this case was Dade County.

Reasoning: Kroll filed the lawsuit in Dade County, asserting that the cause of action accrued there, as the payment location was not specified in their agreement and generally defaults to the creditor's location.

Venue Determination Under Florida Statutes § 47.051

Application: The court applied Florida Statutes § 47.051 to determine that the venue was appropriate in Dade County because the cause of action accrued there, as the payment location defaults to the creditor's location when not specified.

Reasoning: Citing Florida Statutes § 47.051 and relevant case law, the court determined that the cause of action accrued in Dade County because the debtor must seek payment from the creditor, implying that payment was to be made at Kroll's location.