Hinkle v. Continental Motors, Inc.
268 F. Supp. 3d 1312
M.D. Fla.2017Background
- On November 28, 2014, a Cirrus SR22T aircraft crashed in South Carolina after alleged engine failure; plaintiffs (Hinkles and Skinners) allege a defective Kavlico oil transducer and defects/misrepresentations by Cirrus.
- The aircraft was designed, manufactured, sold and delivered in Minnesota; purchaser (Hinkle) is a Florida resident and registered the plane to a Florida LLC.
- Plaintiffs sued Cirrus Design/Industries (Minnesota/Wisconsin connections) and Kavlico (California) in federal court in Florida, asserting both specific and general personal jurisdiction based on defendants’ business activities in Florida.
- Defendants submitted affidavits showing design/manufacture/delivery occurred outside Florida, limited or indirect contacts with Florida (registrations, sales agents, aircraft registered in Florida), and no Florida-based acts giving rise to the crash.
- Plaintiffs offered documentary exhibits (purchase invoices, corporate filings, website printouts, Florida litigation dockets) but no affidavits to rebut defendants’ declarations.
- The court granted defendants’ motions to dismiss for lack of personal jurisdiction and declined to permit jurisdictional discovery on the record presented.
Issues
| Issue | Plaintiff's Argument | Defendant's Argument | Held |
|---|---|---|---|
| Specific jurisdiction under Florida long-arm (claims "arise from" Florida acts) | Defendants sell products in Florida, maintain registrations/agents, Mr. Hinkle purchased plane as a Florida resident — so claims relate to defendants’ Florida contacts | Crash and all relevant design/manufacture/sale/delivery occurred outside Florida (Mexico/California/Minnesota/South Carolina); no Florida conduct gave rise to the claims | No specific jurisdiction: plaintiffs failed to show causes of action "arise from" acts in Florida or any nexus between Florida contacts and the crash |
| General (all-purpose) jurisdiction under Florida long-arm ("at home" test) | Defendants have substantial, continuous activity in Florida (many Cirrus aircraft registered, sales reps, warranty/service network; Kavlico registered, products shipped into Florida) | Neither defendant is incorporated nor has PPB in Florida; sales agents/registration insufficient to render them "at home" in Florida | No general jurisdiction: contacts not sufficient to render defendants essentially "at home" in Florida under Daimler |
| Long-arm enumerated provisions (tort, contract, causing injury) | Tortious acts and breaches injured Florida residents; sale/ongoing warranty ties the contract to Florida | Alleged torts (injury) occurred in South Carolina; contracts required performance/delivery in Minnesota; no Florida-based communications or performance giving rise to claims | Plaintiffs failed to satisfy any enumerated long-arm subsection (tort in Florida, contract breach in Florida, or injury in Florida) |
| Jurisdictional discovery | Plaintiffs requested limited discovery to develop jurisdictional facts | Defendants note plaintiffs never moved for discovery and offered no sworn facts to contradict affidavits | Denied: plaintiffs did not formally move and presented no competent evidence creating a genuine dispute warranting discovery |
Key Cases Cited
- Int’l Shoe Co. v. Washington, 326 U.S. 310 (minimum contacts constitutional standard) (establishes "minimum contacts" due process test)
- Burger King Corp. v. Rudzewicz, 471 U.S. 462 (1985) (contacts and fair warning in specific jurisdiction analysis)
- Goodyear Dunlop Tires Ops., S.A. v. Brown, 564 U.S. 915 (2011) (distinguishing general and specific jurisdiction; forum affiliation requirement)
- Daimler AG v. Bauman, 134 S. Ct. 746 (2014) (general jurisdiction limited to places where corporation is "at home")
- Bristol-Myers Squibb Co. v. Superior Court, 137 S. Ct. 1773 (2017) (specific jurisdiction requires connection between forum and the specific claims)
- Carmouche v. Tamborlee Mgmt., Inc., 789 F.3d 1201 (11th Cir. 2015) (applying Daimler in Eleventh Circuit; limited affiliations insufficient for general jurisdiction)
- United Techs. Corp. v. Mazer, 556 F.3d 1260 (11th Cir. 2009) (long-arm construction and refusal to permit jurisdiction absent forum-related conduct)