Jennifer Williamson v. Rodney Williamson
The Second District reversed a sua sponte forum non conveniens dismissal of a dissolution petition because the trial court neither applied the four-step Kinney/Cortez inconvenient-forum analysis nor identified a specific adequate alternative forum. The court also held the dismissal violated due process because it was entered at a case management conference convened for an unrelated purpose, with no notice to either party and no sworn testimony or evidence. The opinion further notes that Florida Rule of Civil Procedure 1.061 no longer applies in family law cases and that no family law rule addresses inconvenient forum, but that rule 1.061(a) supports requiring comparable considerations.
Key facts
- The Wife filed a petition for dissolution of marriage in Hillsborough County in March 2022, alleging she had been a Florida resident for more than six months before filing; the Husband resided in Louisiana and had lived in Florida only about two months during the marriage.
- The Husband twice moved to dismiss for forum non conveniens, alleging the Wife had relocated with the parties' two children to Utah; the trial court denied both motions while the parties discussed settlement.
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Holdings
- A court may not dismiss an action on forum non conveniens grounds without applying the four-step framework the Florida Supreme Court adopted in Kinney and reaffirmed in Cortez: (1) confirm…
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Why it matters
Although it arises in a dissolution case, the holding is a general civil-procedure ruling of broad practitioner value: forum non conveniens dismissals — in any case type — require an on-the-record Kinney/Cortez… — full analysis with a trial
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