Hartford Accident and Indemnity Company, et al. v. MSP Recovery Claims, Series, LLC, et al.
The Third DCA reversed an order denying Hartford's motion to dismiss for lack of personal jurisdiction. The court held that none of the defensive actions Hartford took constituted abandonment or waiver of its jurisdictional challenge, and that the case was controlled by USAA Casualty Insurance Co. v. MSP Recovery, which declined to extend long-arm jurisdiction under nearly identical circumstances.
Key facts
- MSP Recovery entities filed an action for a pure bill of discovery and declaratory judgment under Florida's Motor Vehicle No-Fault statute, section 627.736.
- MSP's second amended complaint alleged the trial court had specific personal jurisdiction over the Hartford entities.
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Holdings
- Defensive actions undertaken by a defendant do not constitute requests for affirmative relief inconsistent with a challenge to personal jurisdiction and therefore do not waive or abandon…
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Why it matters
This decision reinforces that filing motions to dismiss and other defensive measures does not waive a personal-jurisdiction defense in Florida, and extends USAA Casualty's holding limiting long-arm jurisdiction over… — full analysis with a trial
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