Contesting Personal Jurisdiction in Florida

Contesting personal jurisdiction in Florida is a two-step process oftentimes referred to as the Venetian Salami analysis after a 1989 Florida Supreme Court case. See Kowalski v. Binance Holdings, Ltd., 50 Fla.L.Weekly D2582a (Fla. 3d DCA 2025). The Kowalski case summarized this two-step process as follows: [P]ersonal jurisdiction over a non-resident involves a two-step analysis: a statutory and a constitutional inquiry.  First, the court determines whether the complaint sets forth sufficient jurisdictional allegations to bring the action within Florida's long-arm statute, section 48.193, Florida Statutes. Id. This is accomplished by either tracking the language of the statute without supporting facts or alleging specific facts that...

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