Caiazzo v. American Royal Arts Corp.
73 So. 3d 245
| Fla. Dist. Ct. App. | 2011Background
- This case concerns personal jurisdiction over Caiazzo, who operates Beatles Autographs; ARA sues Caiazzo for FDUTPA, defamation, and unlawful restraint of trade; trial court found both specific and general jurisdiction; Caiazzo had Florida residency and conducted business there during 2004–2005; the internet played a role in the jurisdictional analysis, prompting the court to discuss Zippo and related authorities; Caiazzo filed a notice of voluntary dismissal, but the appellate court elected to issue an opinion due to public importance of internet jurisdiction questions.
Issues
| Issue | Plaintiff's Argument | Defendant's Argument | Held |
|---|---|---|---|
| Whether Florida has specific jurisdiction over Caiazzo for counts I and III | ARA argues Caiazzo’s Florida business activities and statements targeted Florida. | Caiazzo contends minimum contacts are not satisfied for specific jurisdiction. | Yes, specific jurisdiction exists for counts I and III. |
| Whether Florida has specific jurisdiction over Caiazzo for count II (defamation) | ARA alleges Caiazzo’s communications caused defamation in Florida. | Caiazzo argues lack of targeted Florida contact by the defaming statements. | Yes, specific jurisdiction exists for count II based on tortious act within Florida. |
| Whether Florida has general jurisdiction over Caiazzo | ARA suggests extensive Florida activities could support general jurisdiction. | Caiazzo argues activities are not continuous and systematic. | No, general jurisdiction does not exist. |
Key Cases Cited
- Venetian Salami Co. v. Parthenais, 554 So.2d 499 (Fla.1989) (long-arm requires due process analysis beyond mere enumerated acts)
- Internet Solutions Corp. v. Marshall, 39 So.3d 1201 (Fla.2010) (long-arm broad grant; internet activity analyzed for due process)
- Renaissance Health Publ’g, LLC v. Resveratrol Partners, LLC, 982 So.2d 739 (Fla.4th DCA 2008) (interactive website can support jurisdiction under specific jurisdiction analysis)
- Trs. of Columbia Univ. v. Ocean World, S.A., 12 So.3d 788 (Fla.4th DCA 2009) (general jurisdiction via internet activity requires continuous and systematic contacts; careful framework)
- Helicopteros Nacionales de Colombia, S.A. v. Hall, 466 U.S. 408 (U.S.1984) (general jurisdiction requires substantial, continuous contacts; high threshold)
- Asahi Metal Indus. Co. v. Superior Court, 480 U.S. 102 (U.S.1987) (reasonableness of jurisdiction considered in due process analysis)
- Burger King Corp. v. Rudzewicz, 471 U.S. 462 (U.S.1985) (minimum contacts and purposeful availment; avoid talismanic tests)