Edwards v. Airline Support Group, Inc., 138 So. 3d 1209

Edwards appeals a non-final order denying his motion to dismiss for lack of personal jurisdiction in a Florida fraud-transfer suit under §726.108.
ASG, a Florida corporation, sued DAE1 (Indiana) and DAE2 (Kentucky); Edwards is an Indiana resident and alleged affiliate/insider of DAE1.
ASG alleges Edwards received or is receiving distribution of sale proceeds from transfers of DAE1 assets.
The action concerns fraudulent transfers; Edwards is challenged as a transferee, not a transferor.
ASG's third amended complaint and the record lack proof of where the alleged transfer occurred in Florida, raising specific-jurisdiction concerns.
The court held that a fraudulent transfer is not a tortious act under the Florida long-arm statute and reversed the order denying dismissal.

Issue	Plaintiff's Argument	Defendant's Argument	Held
Is a fraudulent transfer a tortious act for long-arm purposes?	ASG argues transfers fall within long-arm reach as a tortuous act.	Edwards contends transfers are not tortious acts under §48.193(1)(a)(2).	Not a tortious act; long-arm unavailable.
Do allegations specify where the transfer occurred to support specific jurisdiction?	ASG contends Florida-based implications justify jurisdiction.	Edwards argues transfer location is unspecified, defeating specific jurisdiction.	Allegations lack where the transfer occurred; no jurisdictional basis shown.

Brown v. Nova Info. Sys., Inc., 903 So.2d 968 (Fla. 5th DCA 2005) (fraudulent transfer not a tortious act for long-arm purposes)
Beta Real Corp. v. Graham, 839 So.2d 890 (Fla. 3d DCA 2003) (fraudulent transfer not a tortious act)
Dinn v. Haynes, 705 So.2d 686 (Fla. 4th DCA 1998) (majority view that fraudulent transfers are not tortious acts)
Friedman v. Heart Inst, of Port St. Lucie, Inc., 863 So.2d 189 (Fla. 2003) (long-arm analysis under 726.108; breadth of relief against transferee)