Marina Dodge, Inc. v. Quinn
134 So. 3d 1103
Fla. Dist. Ct. App.2014Background
- Plaintiff Kristina Quinn purchased a vehicle from New York corporations Marina Dodge, Inc. and Webster Auto Brokers, Inc. in New York in 2003; she later moved to Florida and was injured in a 2007 Broward County collision while driving that vehicle.
- Quinn sued both Auto Dealers in Broward County alleging the dealers sold a defective vehicle that caused the accident; both dealers moved to dismiss for lack of personal jurisdiction.
- Extensive jurisdictional discovery followed; affidavits showed Marina Dodge had limited, mostly internet-based or New York–centered contacts with Florida (e.g., 9–19 auction purchases from Florida auction houses over several years, five warranty-service transactions tied to Florida warranty companies, and $7,500 in payments from a Florida subsidiary tied to financing activities).
- Webster’s only alleged Florida connection was the sale of the vehicle in New York that later was involved in the Florida accident; the dealers’ president denied other Florida contacts and said many contacts were not attributable to Webster.
- The trial court denied the motions, concluding continuous contacts over years supported jurisdiction; the Fourth District reviews personal-jurisdiction rulings de novo and reversed.
Issues
| Issue | Plaintiff's Argument | Defendant's Argument | Held |
|---|---|---|---|
| Specific personal jurisdiction under Fla. Stat. § 48.193(1) (tort/causing injury in Florida) | Quinn argued the dealers’ contacts with Florida (auction purchases, warranty work links, payments from a Florida subsidiary, registration with ADESA Sarasota) support specific jurisdiction because the injury occurred in Florida. | Dealers argued contacts were isolated, internet-based, occurred in New York, and did not show purposeful availment or a connection between their Florida contacts and the accident. | Held: No specific jurisdiction — contacts were random, attenuated, and insufficient to show purposeful availment or that the claim arose from Florida-directed activities. |
| General personal jurisdiction under Fla. Stat. § 48.193(2) (substantial, continuous, systematic contacts) | Quinn argued the cumulative contacts were continuous/systematic enough to subject the dealers to general jurisdiction. | Dealers argued their Florida activity was de minimis (a small fraction of thousands of transactions), with no offices, agents, or marketing in Florida. | Held: No general jurisdiction — contacts did not rise to continuous and systematic business activity required for general jurisdiction. |
Key Cases Cited
- Venetian Salami Co. v. Parthenais, 554 So.2d 499 (Fla. 1989) (adopts two-step long-arm and due-process analysis)
- Int’l Shoe Co. v. Washington, 326 U.S. 310 (1945) (minimum contacts/due process standard)
- Burger King Corp. v. Rudzewicz, 471 U.S. 462 (1985) (purposeful availment and relatedness requirement for specific jurisdiction)
- World‑Wide Volkswagen Corp. v. Woodson, 444 U.S. 286 (1980) (foreseeability alone insufficient for jurisdiction)
- Helicopteros Nacionales de Colombia, S.A. v. Hall, 466 U.S. 408 (1984) (general jurisdiction requires continuous and systematic contacts)