Travel Insurance Facilities, PLC v. Naples Community Hospital, Inc.
A Florida hospital sued UK/German travel insurers under assignments of benefits from foreign patients treated in Florida. The Sixth DCA reversed the denial of the insurers' motions to dismiss, holding the trial court's order was deficient for failing to make findings on the long-arm prong of Venetian Salami, and that in any event the insurers lacked minimum contacts because their only connection to Florida arose from insureds' unilateral travel and a website accessible in Florida but limited to UK residents.
Key facts
- Naples Community Hospital sued UK/German travel insurers in Florida state court based on assignments of benefits from foreign patients who received emergency treatment at the hospital.
- The trial court denied the insurers' motions to dismiss for lack of personal jurisdiction, but issued an order that made no findings regarding satisfaction of Florida's long-arm statute.
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Why it matters
This is an early substantive Sixth DCA opinion on personal jurisdiction that gives defense counsel two usable tools: a procedural requirement that trial courts make findings on both Venetian Salami prongs (an… — full analysis with a trial
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