Hyundai Motor America Corporation v. North American Automotive Services, Inc., 9:20-cv-82102

Background

Third-Party Plaintiff EFN West Palm Motor Sales, LLC sued third-party defendant José Muñoz (CEO of Hyundai Motor America) alleging he conspired and intentionally interfered with EFN’s dealer agreement by authorizing a baseless lawsuit filed by HMA in Florida.
Muñoz is a Tennessee resident (no Florida residence, license, property, or voter registration) who is President/CEO of HMA and HMNA and Global COO of HMC; HMA is California-based.
Muñoz traveled to Florida occasionally, co-signed his daughter’s Miami lease, but declared he performed the challenged decision-making in California and did not direct HMA to file suit in Florida.
EFN relied primarily on an email from Muñoz urging an “extraordinary meeting” about an engine fraud investigation and on circumstantial evidence (including an unrelated prior lawsuit) to allege intentional targeting of Florida.
The Court allowed jurisdictional discovery but found EFN’s evidence insufficient to meet the Florida long-arm “effects test” or otherwise show Muñoz purposefully availed himself of Florida; Muñoz’s declaration was unrebutted.
Conclusion: Court granted Muñoz’s motion for summary judgment for lack of specific personal jurisdiction; it did not reach due process or the corporate-shield doctrine.

Issues

Issue	Plaintiff's Argument	Defendant's Argument	Held
Whether Florida has specific personal jurisdiction over Muñoz for EFN’s intentional-tort claims under Fla. Stat. § 48.193	Muñoz committed out-of-state torts (emails/phone calls/conspiracy) aimed at Florida that caused EFN harm; long-arm statute applies	Muñoz is a nonresident who did not direct the Florida filing, lacked sufficient Florida contacts, and acted via HMA; corporate shield protects him	No specific personal jurisdiction; summary judgment granted for Muñoz
Whether the "effects test" (intentional act aimed at forum causing foreseeable harm) is satisfied	EFN: Muñoz’s emails and alleged conspiracy show intent aimed at Florida and foreseeable harm there	Muñoz: actions occurred in California; he did not target Florida or direct the Florida suit	Effects test not met: EFN’s evidence is too attenuated and unrebutted declaration shows no targeting of Florida
Whether HMA’s filing in Florida can be imputed to Muñoz (civil conspiracy / corporate attribution)	EFN contends Muñoz authorized and directed the suit to harm Napletons, so his contacts should be imputed	Muñoz denies directing forum choice; HMA (not him personally) filed suit	Court found imputation/attribution claim unsupported on the record and deemed EFN’s theory too attenuated; did not need to decide corporate-shield issue
Whether summary judgment is proper at jurisdictional stage	EFN argued discovery would show sufficient contacts; requested denial	Muñoz moved for SJ on lack of jurisdiction and submitted declarations; discovery allowed	Court allowed jurisdictional discovery but held EFN failed to produce affirmative evidence; summary judgment for Muñoz granted

Key Cases Cited

Celotex Corp. v. Catrett, 477 U.S. 317 (summary judgment burden-shifting principles)
Matsushita Elec. Indus. Co. v. Zenith Radio Corp., 475 U.S. 574 (nonmoving party must show more than metaphysical doubt)
Anderson v. Liberty Lobby, Inc., 477 U.S. 242 (mere scintilla of evidence insufficient)
Burger King Corp. v. Rudzewicz, 471 U.S. 462 (purposeful availment / due process framework)
Ford Motor Co. v. Montana Eighth Judicial District Court, 141 S. Ct. 1017 (claims must arise out of or relate to defendant’s forum contacts)
Licciardello v. Lovelady, 544 F.3d 1280 (effects test elements for intentional tort jurisdiction)
Louis Vuitton Malletier, S.A. v. Mosseri, 736 F.3d 1339 (Florida long-arm and specific jurisdiction discussion)
United Techs. Corp. v. Mazer, 556 F.3d 1260 (two-step personal-jurisdiction inquiry)
Calder v. Jones, 465 U.S. 783 (effects test authority)
Gen. Cigar Holdings, Inc. v. Altadis, S.A., 205 F. Supp. 2d 1335 (burden-shifting for jurisdictional proof)