Venetian Salami Co. v. Parthenais
554 So. 2d 499 (1989)
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Rule of Law:
To establish personal jurisdiction over a non-resident defendant, a plaintiff must satisfy a two-part test: first, the defendant's conduct must fall within the scope of the state's long-arm statute, and second, the defendant must have sufficient minimum contacts with the forum state to satisfy constitutional due process requirements.
Facts:
- J.S. Parthenais maintained his principal place of business in Alachua County, Florida.
- Venetian Salami Company is a foreign corporation based in Canada.
- Parthenais alleged that an officer of Venetian Salami contacted him in Alachua County, Florida.
- Parthenais claimed he was hired to provide services to help Venetian Salami determine the collectability of a large delinquent account.
- The alleged agreement stated that Venetian Salami would reimburse Parthenais for his expenses.
- According to the alleged agreement, payment was to be made to Parthenais at his place of business in Alachua County, Florida.
- Parthenais asserted that he performed the agreed-upon services, but Venetian Salami refused to pay him.
Procedural Posture:
- J.S. Parthenais filed a lawsuit for damages against Venetian Salami Company in a Florida trial court.
- Venetian Salami filed a motion to dismiss the suit for lack of personal jurisdiction.
- The parties filed conflicting affidavits concerning Venetian Salami's contacts with Florida.
- The trial court dismissed the suit, finding that Venetian Salami lacked sufficient minimum contacts with Florida.
- Parthenais, as appellant, appealed the dismissal to the Florida First District Court of Appeal.
- The First District Court of Appeal reversed the trial court's order, holding that satisfying the long-arm statute was sufficient to establish jurisdiction.
- Venetian Salami, as petitioner, appealed to the Supreme Court of Florida, which accepted the case due to a conflict among the district courts of appeal.
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Issue:
Does a Florida court obtain personal jurisdiction over a non-resident defendant solely by the plaintiff alleging facts that fall within Florida's long-arm statute, or must the court also conduct a separate inquiry into whether the defendant has sufficient minimum contacts with Florida to satisfy constitutional due process?
Opinions:
Majority - Grimes, Justice
No. A court cannot obtain personal jurisdiction over a non-resident defendant solely by meeting the long-arm statute's requirements; a separate inquiry into whether the defendant has sufficient minimum contacts to satisfy due process is also required. By enacting the long-arm statute, the legislature determined the basis for jurisdiction under state law, but it did not, and could not, address the federal constitutional requirement of minimum contacts on a case-by-case basis. Citing 'International Shoe Co. v. Washington' and 'Burger King Corp. v. Rudzewicz,' the court affirmed that due process requires a defendant to have certain minimum contacts with the forum such that the lawsuit does not offend 'traditional notions of fair play and substantial justice.' The court established a two-part inquiry for jurisdiction: 1) the complaint must allege sufficient facts to bring the action within the long-arm statute, and 2) the defendant must have sufficient minimum contacts to satisfy due process. When affidavits from the parties present conflicting facts on the issue of jurisdiction, the trial court must hold a limited evidentiary hearing to resolve the factual dispute.
Analysis:
This decision solidifies a mandatory two-part test for personal jurisdiction in Florida, ensuring that state courts align their jurisdictional analyses with federal due process standards established in 'International Shoe' and its progeny. The ruling clarifies that Florida's long-arm statute reaches only as far as the Due Process Clause permits, rejecting the notion that satisfying the statute automatically confers jurisdiction. The most significant procedural innovation is the requirement for a limited evidentiary hearing when jurisdictional facts are contested through conflicting affidavits. This prevents dispositive rulings based solely on a 'battle of the affidavits' and ensures a more developed factual record for the crucial threshold question of jurisdiction.
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