Tawana Carmouche v. Tamborlee Management, Inc., 2015 U.S. App. LEXIS 10029

Plaintiff Tawana Carmouche was injured during a shore excursion in Belize operated by Tamborlee Management, Inc., a Panama corporation; she sued Tamborlee in the Southern District of Florida for negligence.
Tamborlee moved to dismiss for lack of personal jurisdiction; district court allowed jurisdictional discovery and later granted Tamborlee’s motion.
Tamborlee’s contacts with Florida: a Citibank account handled through Miami, insurance from Florida companies, membership in a Florida trade association, a UCC financing statement filed in Florida, and contracts with Carnival that listed a Key West P.O. box as Tamborlee’s “principal place of business” and contained forum-selection clauses consenting to Southern District of Florida jurisdiction.
Tamborlee submitted declarations and documents asserting the Key West P.O. box and another Key West address were errors or not affiliated with Tamborlee; most operational addresses were in Panama or Belize.
Carmouche did not argue specific jurisdiction; the dispute focused on whether Florida courts had general (all-purpose) jurisdiction over Tamborlee under Florida’s long-arm statute and the Due Process Clause.

Issue	Plaintiff's Argument	Defendant's Argument	Held
Whether Florida has general personal jurisdiction over Tamborlee	Tamborlee’s Florida-related contacts (bank account, insurance, trade membership, UCC filing, Carnival contracts with Florida forum clause and Key West address) suffice for general jurisdiction	Tamborlee’s contacts are isolated/minor; primary operations and incorporation are abroad; Key West addresses were errors and do not make it “at home” in Florida	Court held no general personal jurisdiction; contacts not “continuous and systematic” to render Tamborlee essentially at home in Florida

International Shoe Co. v. State of Wash., 326 U.S. 310 (established standard that due-process requires contacts to be such that maintaining suit does not offend traditional notions of fair play and substantial justice)
Perkins v. Benguet Consol. Min. Co., 342 U.S. 437 (Ohio could exercise general jurisdiction where wartime circumstances made it the corporation’s temporary principal place of business)
Helicopteros Nacionales de Colombia, S.A. v. Hall, 466 U.S. 408 (contacts such as purchases and training trips did not support general jurisdiction)
Goodyear Dunlop Tires Operations, S.A. v. Brown, 564 U.S. 915 (general jurisdiction exists only where affiliations render a corporation essentially at home in the forum)
Daimler AG v. Bauman, 571 U.S. 117 (paradigm forums are place of incorporation and principal place of business; general jurisdiction in other forums is rare)
Keeton v. Hustler Magazine, 465 U.S. 770 (discussed Perkins as situational surrogate for principal place of business)
Fraser v. Smith, 594 F.3d 842 (11th Cir.) (similar holding that tourism operator’s U.S.-directed activities did not establish general jurisdiction)