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.

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