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.
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