Henderson v. Elias, 56 So. 3d 86

Henderson and Star-dale LLC formed in 2005; Stardale’s operating agreement contemplated dissolution upon Elias’s death.
Elias died in 2008, but Stardale was not dissolved as required by the agreement.
Estate filed suit in New York for breach of the operating agreement; New York action required by the agreement’s forum clause.
During New York proceedings, the estate filed a Florida probate petition seeking to preserve assets and enjoin disposition of Stardale’s assets.
The probate court initially dismissed Stardale for improper service; Henderson’s forum non conveniens challenge was denied.
Estate later amended the petition to rely on Florida probate court “inherent jurisdiction” to monitor the estate; Stardale was served via its registered agent and challenged jurisdiction at hearings.

Issue	Plaintiff's Argument	Defendant's Argument	Held
Whether the amended petition states sufficient jurisdictional facts to subject Stardale to Florida long-arm jurisdiction	Elias claims Stardale’s Florida activities and assets give rise to jurisdiction	Stardale contends petition lacks Florida-based conduct or contacts and therefore falls outside 48.193(1)	Petition insufficient; lack of jurisdictional facts; remand without prejudice

Venetian Salami Co. v. Parthenais, 554 So.2d 499 (Fla. 1989) (two-step approach to asserting personal jurisdiction under Florida law)
Balboa v. Assante, 958 So.2d 573 (Fla. 4th DCA 2007) (requires affidavits when initial pleading shows basis for jurisdiction; hearing only if conflict)
Woods v. Nova Cos. Belize Ltd., 789 So.2d 617 (Fla. 4th DCA 1999) (protects that pleading burden before jurisdictional discovery)
Hall v. Tungett, 980 So.2d 1289 (Fla. 2d DCA 2008) (confirms initial burden on pleadings before evidence on minimum contacts)
Beasley v. Diamond R. Fertilizer Co., 710 So.2d 1025 (Fla. 5th DCA 1998) (limits corporate jurisdiction to company conduct, not shareholder actions)