USAA Casualty Insurance Company, et al. v. MSP Recovery Claims, Series LLC, et al.
The Third DCA consolidated three appeals and reversed Miami-Dade circuit court orders that had denied motions to dismiss for lack of personal jurisdiction in PIP-related pure bill of discovery actions brought by MSP Recovery against non-resident insurers USAA, MGA, and Progressive. The court held that bare allegations of 'substantial and not isolated activities in Florida' are insufficient to establish either general or specific jurisdiction under Florida's long-arm statute, and that none of the insurers waived that defense despite participating in prolonged class certification proceedings.
Key facts
- MSP Recovery and affiliated entities filed three separate Miami-Dade circuit court actions seeking pure bills of discovery under Florida's PIP Statute (§627.376), later amending each complaint to add declaratory relief and class action claims on behalf of Medicaid and Medicare managed care organization assignors.
- Each case was stayed for approximately two years while MSP Recovery unsuccessfully sought to disqualify the insurers' shared counsel; after the Third DCA rejected disqualification and the Florida Supreme Court denied review, litigation resumed and the complaints were further expanded.
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Holdings
- To establish general jurisdiction under §48.193(2), a plaintiff must plead ultimate facts showing contacts so continuous and systematic as to render the defendant essentially at home in…
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