Ornella Pianezza and Andrea Artioli v. MIA Collection Services LLC, 2022-1580

MIA Collection Services LLC sued Hyba General Trading LLC, Mattia Asti Brun, Ornella Pianezza, and Andrea Artioli over allegations of selling counterfeit handbags instead of genuine ones.
Hyba is based in Dubai; Pianezza and Artioli are European citizens who reside outside Florida but allegedly participated in making fraudulent representations about handbag authenticity.
The claims against Pianezza and Artioli include fraud in the inducement, negligent misrepresentation, breach of express warranty, and conspiracy, grounded largely in their alleged communications into Florida and knowledge of MIA Collection’s Florida location.
Pianezza and Artioli moved to dismiss for lack of personal jurisdiction, relying on the corporate shield doctrine and arguing minimal contacts with Florida.
The trial court denied their motion without an evidentiary hearing, finding the complaint sufficiently alleged personal jurisdiction.
This is an appeal of the trial court’s denial of the motion to dismiss for lack of personal jurisdiction.

Issue	Plaintiff's Argument	Defendant's Argument	Held
Sufficiency under Florida long-arm statute	Defendants committed intentional torts (fraud) via communications into Florida causing injury there	Actions were solely in corporate capacity and shielded by corporate shield doctrine	Complaint sufficiently alleges tortious acts in Florida
Applicability of corporate shield doctrine	Does not protect when employee/officer commits intentional tort	Doctrine bars personal jurisdiction for acts in corporate capacity	Exception applies; fraud claim defeats shield
Evidence needed to shift burden to plaintiff	Defendants’ affidavits were self-serving, not enough to shift burden	Affidavits/declarations refute jurisdictional allegations	Defendants’ evidence was legally insufficient; no shift in burden
Whether minimum contacts (due process) exist	Defendants knowingly directed actions at Florida, causing harm there	Minimal contact, did not purposely avail themselves of FL jurisdiction	Minimum contacts exist; jurisdiction comports with due process

Wendt v. Horowitz, 822 So. 2d 1252 (Fla. 2002) (establishes two-prong test for personal jurisdiction under Florida law)
Kitroser v. Hurt, 85 So. 3d 1084 (Fla. 2012) (corporate shield doctrine does not protect officers committing fraud)
Doe v. Thompson, 620 So. 2d 1004 (Fla. 1993) (officer personally liable for intentional torts even if committed on behalf of corporation)
Calder v. Jones, 465 U.S. 783 (1984) (intentional torts expressly aimed at forum state satisfy minimum contacts for personal jurisdiction)
Acquadro v. Bergeron, 851 So. 2d 665 (Fla. 2003) (affidavits must be legally sufficient to shift jurisdictional burden to plaintiff)