Port Royal Property, LLC v. Woodson Electric Solutions, Inc.
The Third District reversed an order transferring venue from Miami-Dade to Collier County because the trial court applied the four-part forum non conveniens analysis from Kinney System, Inc. v. Continental Insurance Co. and Rule 1.061 to an intrastate transfer under section 47.122. The court clarified that its earlier Westchester Fire decision merely spoke of transfer being 'in the spirit of Kinney' as dicta and did not require the Kinney analysis for county-to-county transfers, aligning the Third District with the First, Second, and Fourth Districts.
Key facts
- Port Royal Property, LLC sought to transfer venue from Miami-Dade County to Collier County in a civil dispute with Woodson Electric Solutions, Inc.
- The trial court granted the transfer motion, applying the four-part forum non conveniens analysis from Kinney System, Inc. v. Continental Insurance Co. and Florida Rule of Civil Procedure 1.061.
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Why it matters
This opinion resolves recurring confusion in the Third District over whether the Kinney/Rule 1.061 forum non conveniens factors govern intra-Florida venue transfers, expressly limiting Westchester Fire to dicta and… — full analysis with a trial
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