PayDay Solutions, LLC v. JTL Staffing and Payroll, LLC
3:23-cv-00828
M.D. Fla.Apr 14, 2025Background
- Plaintiff, Payday Solutions, alleges that Defendants Carla and James Lowdell closed their business, JTL Staffing and Payroll, and transferred all assets to Elite Management Solutions to shield income from creditors.
- Elite Management Solutions is alleged to be a mere alter ego of JTL, sharing principals, customers, operations, and geography.
- Payday asserts the Court has personal jurisdiction over Elite because Elite conducts business in Florida and allegedly caused harm there.
- Elite moved to dismiss Count V (alter ego claim) on grounds that the Court lacks personal jurisdiction.
- The Court considered whether alter ego/jurisdictional allegations are sufficient on the pleadings to establish personal jurisdiction over Elite.
- The ruling is made on a motion to dismiss; the case remains ongoing.
Issues
| Issue | Plaintiff's Argument | Defendant's Argument | Held |
|---|---|---|---|
| Personal jurisdiction over Elite | Elite’s business in Florida and harm to Payday | No sufficient Florida contacts; improper pleading | Sufficient allegations under alter ego theory; motion denied |
| Alter ego liability/jurisdiction | Elite is JTL's alter ego; veil-piercing applies | No showing of improper conduct or close connection | Allegations plausible; defer for factual development |
Key Cases Cited
- Oriental Imports & Exports, Inc. v. Maduro & Curiel’s Bank, N.V., 701 F.2d 889 (11th Cir. 1983) (personal jurisdiction in diversity cases is determined under state long-arm statutes)
- Meier v. Sun Int’l Hotels, Ltd., 288 F.3d 1264 (11th Cir. 2002) (two-step personal jurisdiction analysis: statutory and constitutional)
- Johnson Enters. of Jacksonville, Inc. v. FPL Grp., Inc., 162 F.3d 1290 (11th Cir. 1998) (defining improper conduct in veil-piercing context)
- Dania Jai-Alai Palace, Inc. v. Sykes, 450 So.2d 1114 (Fla. 1984) (corporate veil-piercing requires proof of corporation as sham and improper conduct)