Brown v. NAGELHOUT, 84 So. 3d 304

Browns filed suit in Broward County over a collision occurring in Pasco County; Nagelhout (individual) resides in Pasco and Helena Chemical has business residence in Pasco; CSX's domicile and agent locations are in other counties; trial court granted transfer to Pasco under a reading of Enfinger; Fourth District affirmed the transfer; Florida Supreme Court granted review to address conflict with other districts; Court recedes from Enfinger and remands for proceedings consistent with opinion.

Issue	Plaintiff's Argument	Defendant's Argument	Held
Whether Enfinger should be receded in favor of plain statute text	Brown argues Enfinger misinterprets statutes.	Nagelhout/Helena argue Enfinger should control venue.	Yes, recede; statutes govern venue without Enfinger.
What is the proper venue rule under Florida statutes 47.011, 47.021, 47.051 when multiple defendants reside in different counties	Plaintiff may select any county where any defendant resides.	Defendants contend shared residency limits venue to common counties.	Plaintiff may choose any county where any defendant resides.

Enfinger v. Baxley, 96 So.2d 538 (Fla.1957) (joint residency rule where co-defendants reside in different counties)
Aladdin Insurance Agency, Inc. v. Jones, 687 So.2d 937 (Fla.3d DCA 1997) (rejected joint residency limitation when no single common county)
Reliable Electrical Distribution Co. v. Walter E. Heller & Co. of Louisiana, Inc., 382 So.2d 1287 (Fla.1st DCA 1980) (held joint residency rule not applicable where not all defendants share a common county)
Doonan v. Poole, 114 So.2d 504 (Fla.2d DCA 1959) (acknowledged limits of joint residency rule)
Brady v. Times-Mirror Co., 39 P. 209 (Cal.1895) (California rule cited as distinguishable; Florida uses plaintiff-friendly venue)
Allied-Signal, Inc. v. Director, Div. of Taxation, 504 U.S. 768 (1992) (standards for departing from precedent; consider unsoundness and reliance)