PLEAD SUFFICIENT ALLEGATIONS SUPPORTING PERSONAL JURISDICTION

Remember when drafting a complaint, jurisdictional allegations are important. This is especially true if you are suing a defendant located outside of Florida. Jurisdictional allegations should be plead with detail supporting the factual basis for personal jurisdiction. There should be a consideration that a nonresident defendant may challenge personal jurisdiction and the very FIRST STEP in a court’s analysis in determining personal jurisdiction “is to determine whether the complaint alleges sufficient jurisdictional facts to bring the action within the ambit of Florida’s long-arm statute, section 48.193, Florida Statutes.” Williamson v. Prime Sports Marketing, LLC, 45 Fla.L.Weekly D268a (Fla. 3d DCA 2020). ...