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

Suing a person or entity for personal injury in Florida requires not only establishing the party’s responsibility for the injury, but also navigating a whole array of jurisdictional matters. In Hatton v. Chrysler Canada, Inc., the U.S. District Court for the Middle District of Florida takes on a couple of the most common jurisdictional issues: personal jurisdiction and the statute of limitations.

Ms. Hatton was injured in a January 2009 Florida car accident while she was a passenger in the back seat of a 1999 Chrysler 300 M driven by Christopher Shelton. She alleged that various components of the vehicle failed to work on impact, causing Hatton serious injury. Hatton sued the car’s manufacturer, Chrysler Canada Inc., in state court. She asserted claims of negligence and strict products liability. CCI removed the case to the federal District Court and filed a motion to dismiss the action, claiming that the court did not have personal jurisdiction over the company and that the claims were barred by the applicable statute of limitations.

Denying the motion, the court found that jurisdiction was appropriate under the Florida “long-arm” statute. Section (1)(f)(2) of the law provides personal jurisdiction over a person or entity that causes “injury to persons or property within this state arising out of an act or omission by the defendant outside this state, if, at or about the time of the injury . . . [p]roducts, materials, or things processed, serviced, or manufactured by the defendant anywhere were used or consumed within this state in the ordinary course of commerce, trade, or use.” Here, although CCI is a Canadian company and does not rent or own property in Florida, Hatton alleged that it ships thousands of the vehicles it makes to the Sunshine State each year, including the 300 M involved in the accident.

The court found that applying the long-arm statute in this case did not run afoul of the U.S. Constitution’s due process protections because CCI had sufficient “minimum contacts” with the state. CCI specifically assembled the 300 M for sale in the U.S., thereby invoking the protections and benefits of laws of the individual states, including Florida, according to the court. On the balance, applying jurisdiction in this case also did not offend notions of “fair play and substantial justice,” the court further ruled, particularly noting the State of Florida’s substantial interest in protecting drivers and passengers on its roads from potentially unsafe vehicles.

Meanwhile, the court ruled that the action was not barred by Canada’s two-year statute of limitations – generally requiring Hatton to sue within two years of the accident – because the matter may be subject to equitable tolling. Hatton claimed that Chrysler fraudulently identified Chrysler United States as the 300 M manufacturer, a move that delayed his filing of a complaint against CCI, the actual manufacturer and responsible party. Because resolution of this dispute required the consideration of evidence not yet in the record, the court declined to dismiss the action of statute of limitations grounds.

If you or a loved one has been injured in an accident, contact the South Florida car accident lawyers at Anidjar & Levine. From offices in Ft. Lauderdale, we serve clients throughout the area, including in Boca Raton, Coral Springs and Pompano Beach. Call us toll-free at 800-747-3733 or contact us online to schedule a free consultation.

Related blog posts:

Court Defends Right to Lawyer in Florida Car Accident Cases – Howard v. Palmer

No Seatbelt Cuts Florida Car Accident Victim’s Recovery – Disla v. Blanco