Tess v. Springfield, Inc.
A Florida plaintiff injured by a Springfield 1911-A1 pistol sued the manufacturer plus a dissolved predecessor entity (Springfield Guns) and the manufacturer's parent holding company. Applying Florida's long-arm statute, the court dismissed both for lack of personal jurisdiction: the predecessor had exited the firearms business in 1992 and dissolved in 2016, so no connexity existed with a 2017-manufactured pistol, and the holding company had no operations of its own. The court also rejected the plaintiff's 'reverse alter-ego' theory of jurisdiction, holding that no Florida authority permits jurisdiction over a nonresident parent based on its being controlled by another nonresident defendant.
Key facts
- Plaintiff injured by a 2017-manufactured Springfield 1911-A1 pistol sued the current manufacturer, a dissolved predecessor entity (Springfield Guns, which exited the firearms business in 1992 and dissolved in 2016), and the manufacturer's nonresident parent holding company.
- Trial court dismissed all defendants for lack of personal jurisdiction under Florida's long-arm statute.
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Why it matters
Useful for defense counsel resisting jurisdiction over holding companies and dormant predecessor entities in Florida products cases: the opinion collects the three Knepfle/Schwartzberg routes to parent-company… — full analysis with a trial
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