Jurisdiction Over Third Parties in Florida Car Accident Cases – Marina Dodge v. Quinn

When a car accident happens, most of the finger pointing that follows goes on between the drivers of the vehicles involved (and their insurance companies). There is a wide variety of third parties, however, who may also be responsible for a crash. In Marina Dodge v. Quinn, Florida’s Fourth District Court of Appeals explains that injured persons who go after one or more of those third parties better be sure they’re doing so in the right state.

Ms. Quinn purchased her car in New York from two local companies, Marina Dodge and Webster Auto Brokers. She was living in Florida when she was later involved in a 2007 vehicle collision in the Sunshine State. Quinn sued the companies in Florida, alleging that the car was defective and that this defect led to the accident. A trial court denied the companies’ motion to dismiss the complaint, in which they argued that the court didn’t have personal jurisdiction over them.

Reversing the decision on appeal, however, the Fourth District held that neither company had sufficient contacts with the State of Florida to justify the trial court exercising jurisdiction over them. As the Court explained, “personal jurisdiction can exist in two forms: ‘specific,’ in which the alleged activities or actions of the defendant are directly connected to the forum state, and ‘general,’ in which the defendant’s connection with the forum state is so substantial that no specific or enumerated relationship between the alleged wrongful actions and the state is necessary.”

Here, Quinn argued that the local court had specific personal jurisdiction over the companies because they allegedly committed tortious act in the state and their acts or omissions outside of Florida caused injury to persons or property within the state. The Fourth District disagreed. With respect to Webster Auto, the Court said the only contact the company had with the state was that it sold the car to Quinn in New York several years before the accident. “This contact alone has been held to be insufficient to support an exercise of personal jurisdiction over a nonresident defendant,” the Court noted.

The Court also found that Marina Dodge’s additional contacts with the state weren’t enough to establish jurisdiction. Indeed, the evidence showed only that the company engaged in a handful of transactions with Florida corporations over the years. That included purchasing 19 vehicles from a dealer in Orlando and performing service on a few vehicles in New York pursuant to extended warranties the owners bought from a company in Florida. “We cannot conclude that the Auto Dealers purposefully directed its activities at consumers or businesses in Florida,” the Court concluded, “nor can we find that the personal injury litigation results from alleged injuries that arise out of or relate to those activities.”

As a result, the Court reversed the lower court’s decision and remanded the case with instructions that it be dismissed.

It’s important to note that the Court didn’t weigh in on Quinn’s actual claims against the companies. It simply said that she couldn’t pursue the claims in a state court in Florida. If you or a loved one has been injured in a car accident, contact the South Florida car accident attorneys at Anidjar & Levine. We represent clients throughout the region, including in Ft. Lauderdale, Boca Raton and Coral Springs. Call us toll-free at 800-747-3733 or fill out and submit an online Contact Us form to schedule a free consultation.

Related blog posts:

Jurisdictional Issues in Florida Personal Injury Cases – Hatton v. Chrysler Canada, Inc.

Single Car Accidents and Third-Party Liability – O’Malley v. Ranger Construction Industries

Proving Injury in Florida Car Accident Cases – Pack v. Geico