A Florida court recently ruled in a case involving Meyer Werft GmbH & Company, KG, and Jocelyne Humain, determining that the court lacked personal jurisdiction over the German shipbuilding company. The ruling affects how personal jurisdiction is established in injury cases involving foreign corporations.
The case, Meyer Werft GmbH & Company, KG v. Jocelyne Humain, was filed in the Third District Court of Appeal of Florida under docket number 3D19-1737. The court's decision was issued on May 6, 2020, and it reversed a lower court's order that had denied Meyer Werft's motion to dismiss the case.
Background
Jocelyne Humain, a U.S. citizen residing in Miami-Dade County, Florida, was employed by Cintas Corporation to make uniforms for Royal Caribbean Cruise Ltd. In March 2016, while working aboard the Ovation of the Seas, she suffered a wrist injury after tripping over electrical cords. Initially, Humain filed a lawsuit against Cintas and Royal Caribbean. Later, she added Meyer Werft, the German company that built the Ovation of the Seas, as a defendant.
Humain's complaint included three counts against Meyer Werft: Jones Act negligence, unseaworthiness of the vessel, and negligence based on her alleged status as a passenger. She argued that Meyer Werft was subject to personal jurisdiction in Florida due to its business dealings with Florida cruise companies and claimed that the company breached an employment contract by not providing seaman's benefits after her injury.
Meyer Werft responded by filing a motion to dismiss, asserting that the court lacked personal jurisdiction. The company provided a sworn declaration from Jens Sandmann, its head of legal affairs, stating that Meyer Werft was a German corporation with no employees in Florida and no business operations in the state.
The Ruling
The court ruled in favor of Meyer Werft, stating that Humain failed to provide sufficient evidence to establish personal jurisdiction. The judges, including Lindsey, Miller, and Lobree, pointed out that Humain did not refute the sworn proof submitted by Meyer Werft. The court emphasized, "Humain failed to establish the minimum contacts necessary for general or specific jurisdiction under Florida’s long-arm statute."
Furthermore, the court noted that Humain did not present any sworn proof to counter Meyer Werft's claims. The judges stated, "If no such sworn proof is forthcoming from the plaintiff as to the basis for jurisdiction, the trial court must grant the defendant’s motion to dismiss." As a result, the court reversed the lower court's decision and instructed it to grant the motion to dismiss.
Impact
This ruling has significant implications for personal injury cases involving foreign corporations. It clarifies the burden of proof required for establishing personal jurisdiction in Florida courts. The court's decision reinforces that plaintiffs must provide sufficient evidence to support their claims of jurisdiction, especially when dealing with defendants based outside the United States.
For foreign corporations, this ruling may provide a clearer pathway to dismiss cases where they have minimal or no connections to the state. It also highlights the importance of sworn declarations in jurisdictional disputes, emphasizing that failure to contest such declarations can lead to dismissal.
What's Next
Humain may seek to appeal the decision, but details were not available in the court filing regarding any related cases or potential next steps. The ruling sets a precedent for how courts will handle similar jurisdictional challenges in the future.