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3rd DCAJuly 29, 2026Affirmed⭐ Notable

John Gregorian v. New Century Alhambra Automobiles, Inc.

Case No. 2025-2538

The Third District affirmed the dismissal of a small claims action for lack of personal jurisdiction and the denial of the plaintiff's request for jurisdictional discovery. Because the statement of claim was unverified and pleaded jurisdiction only in conclusory terms, and because the defendant's jurisdictional affidavit went uncontroverted by any sworn proof, the trial court acted within its wide discretion in refusing discovery and granting dismissal without an evidentiary hearing.

Key facts

  • John Gregorian filed a small claims statement of claim in Monroe County Court against New Century Alhambra Automobiles, Inc.
  • The statement of claim was unverified and contained only conclusory allegations of personal jurisdiction over the defendant.
  • +2 more key facts with a free trial

Holdings

  • Denial of a request for jurisdictional discovery is reviewed for abuse of discretion, and a trial court enjoys wide latitude in managing discovery; refusing jurisdictional discovery is not…
  • +1 more holding with a free trial

Why it matters

This opinion is a clean, citable restatement of the burden-shifting sequence every Florida practitioner faces on a personal jurisdiction motion, and it applies that sequence in the small claims setting where litigants… — full analysis with a trial

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