Young Bock Shim v. Frederick F. Buechel, etc., 339 So.3d 315

Creditors (Buechel and Pappas) obtained a Florida money judgment against debtor Shim and Cellumed.
Post-judgment discovery showed Shim had about $4,000,000 in proceeds (a negotiable instrument) stored at his home in South Korea.
Creditors moved under §56.29(6), Fla. Stat., to compel Shim to turn over those proceeds to satisfy the Florida judgment.
The trial court denied relief, reasoning Florida courts lack in rem/quasi in rem jurisdiction over foreign property and could not compel turnover.
The Fifth District reversed in Buechel, holding §56.29(6) allows a court with in personam jurisdiction over a defendant to order that defendant to act on foreign assets; the Fourth District’s Sargeant decision conflicted.
The Florida Supreme Court approved the Fifth District, holding a trial court may order a defendant over whom it has personal jurisdiction to act on foreign property under §56.29(6), and disapproving Sargeant to the extent it held otherwise.

Issue	Plaintiff's Argument	Defendant's Argument	Held
Whether §56.29(6) authorizes a Florida court to compel a judgment debtor to act regarding property located outside Florida	§56.29(6) plainly authorizes courts to levy any property of the judgment debtor, including foreign assets, when the court has in personam jurisdiction	Florida courts lack in rem or quasi in rem jurisdiction over foreign property; therefore they cannot compel turnover of property located abroad	Yes. A court with in personam jurisdiction may order a defendant to act on foreign property under §56.29(6); Sargeant is disapproved to the extent it holds otherwise
Whether policy/extraterritorial concerns preclude applying §56.29(6) to foreign property	The statute’s text is clear and controls; policy concerns cannot override an unambiguous statute	Policy arguments counsel against extraterritorial reach and limit application	Court relied on the statute’s plain meaning and controlling precedent on in personam power; extraterritorial application is permitted only when the court has personal jurisdiction over the defendant (and no broader extraterritorial reach is implied)

Sargeant v. Al-Saleh, 137 So. 3d 432 (Fla. 4th DCA 2014) (held trial court lacked jurisdiction to compel turnover of property located outside Florida)
Gen. Elec. Cap. Corp. v. Advance Petroleum, Inc., 660 So. 2d 1139 (Fla. 3d DCA 1995) (recognized that in personam jurisdiction can support orders that indirectly affect out-of-state property)
Fall v. Eastin, 215 U.S. 1 (1909) (historic U.S. Supreme Court rule that courts may compel defendants to act concerning property outside the forum)
Morrison v. Nat’l Austl. Bank Ltd., 561 U.S. 247 (2010) (statutes lacking a clear indication of extraterritorial application have none)
State v. Peraza, 259 So. 3d 728 (Fla. 2018) (Florida Supreme Court principle that clear statutory text controls over policy considerations)