ROBERT J. TRIFFIN VS. BOARD OF COUNTY COMMISSIONERS Â HERNANDO COUNTY(DC-7774-15, MONMOUTH COUNTY AND STATEWIDE), A-1956-15T2

Hernando County Board of County Commissioners (Florida public entity) issued a $176.93 refund check to John and Melissa Giordano relating to Florida property.
The Giordanos cashed the check with a New Jersey check-cashing business (Friendly); the Board's bank denied payment because the check had been previously cashed electronically.
Friendly assigned its rights to Robert J. Triffin, who sued the Giordanos and the Board in Monmouth County, New Jersey (Special Civil Part).
Only the Board answered and promptly moved to dismiss for lack of personal jurisdiction.
The Law Division granted the motion and dismissed the Board without prejudice; Triffin appealed arguing the FDCPA venue provision (15 U.S.C. § 1692i) required Monmouth County and thus the court had jurisdiction over the Board.

Issue	Plaintiff's Argument	Defendant's Argument	Held
Whether the New Jersey court had personal jurisdiction over a Florida county board	Triffin: FDCPA venue provision (§1692i) required filing in Monmouth County, so court has jurisdiction over all defendants including the Board	Board: It lacks sufficient contacts with New Jersey; venue under FDCPA does not confer personal jurisdiction	Court: FDCPA venue is irrelevant to personal jurisdiction; Board lacked minimum contacts and dismissal for lack of personal jurisdiction affirmed

YA Global Invs., L.P. v. Cliff, 419 N.J. Super. 1 (App. Div. 2011) (de novo review of jurisdictional determinations with deference to factual findings)
Charles Gendler & Co. v. Telecom Equip. Corp., 102 N.J. 460 (1986) (New Jersey courts exercise jurisdiction over nonresidents only as U.S. Constitution allows)
Blakey v. Continental Airlines, 164 N.J. 38 (2000) (due process requires minimum contacts and fairness)
Int'l Shoe Co. v. Washington, 326 U.S. 310 (1945) (established minimum contacts test for personal jurisdiction)
Rova Farms Resort, Inc. v. Inv'rs Ins. Co., 65 N.J. 474 (1974) (trial court factual findings will not be disturbed if supported by credible evidence)
Manalapan Realty v. Manalapan Twp. Comm., 140 N.J. 366 (1995) (no deference to trial court's application of law to facts on appeal)
Lebel v. Everglades Marina, Inc., 115 N.J. 317 (1989) (focus on relationship among defendant, forum, and litigation for specific jurisdiction)
Waste Mgmt. v. Admiral Ins. Co., 138 N.J. 106 (1994) (purposeful availment standard)
Jacobs v. Walt Disney World Co., 309 N.J. Super. 443 (App. Div. 1998) (distinguishing specific and general jurisdiction)
Rutgers—The State Univ. v. Fogel, 403 N.J. Super. 389 (App. Div. 2008) (interpreting FDCPA venue provision applicability)