The Third District Court of Appeal in Florida recently ruled on a significant arbitration dispute involving Rafael Lopes Brasileiro Martim and Cattleya PTC. The court's decision, filed on November 4, 2026, addresses the complexities surrounding arbitration agreements and jurisdictional issues in legal disputes. This ruling affects both parties and could have implications for future arbitration cases in Florida.

The case stems from a lawsuit filed by Cattleya PTC, a Swiss private trust company, against Martim and his company, MME Martim, LLC. Cattleya PTC accused Martim and his company of failing to return $10 million that was transferred to them for investment purposes. The court's ruling clarifies the legal standing of the parties involved and the enforceability of arbitration agreements.

Background

Rafael Lopes Brasileiro Martim, also known as R. Martim, is the chief executive officer of MME Martim, LLC, which is a Florida limited liability company. Cattleya PTC, the plaintiff in this case, alleged that Martim and his company had failed to account for or return the funds that were entrusted to them for investment. The lawsuit included claims of conversion, unjust enrichment, and the imposition of a constructive trust.

The dispute escalated when Martim and his company sought to dismiss the lawsuit and compel arbitration based on a contract that mandated disputes be resolved through arbitration in London. They argued that the trial court lacked jurisdiction and that the case should be dismissed based on several factors, including lack of standing and improper venue. However, they did not provide any supporting affidavits or evidence to bolster their claims.

The trial court denied their motion to dismiss, prompting Martim and his company to appeal the decision. The appeal was filed under docket number 3D2025-2106, and the case was heard by the Third District Court of Appeal of Florida.

The Ruling

The court ruled on the appeal, affirming part of the trial court's decision and dismissing another part for lack of jurisdiction. The judges noted that the denial of a motion to dismiss is generally considered a non-final order, and the court has limited jurisdiction to review such orders.

The court stated, "Without jurisdiction, there is only one action we can take: we must dismiss." This highlights the importance of jurisdiction in legal proceedings.

Specifically, the court found that it did not have jurisdiction to hear appeals of non-final orders denying motions to dismiss based on lack of standing or failure to join an indispensable party. However, the court did have jurisdiction to review the denial of the motion to dismiss based on the forum non conveniens argument, which allows a court to dismiss a case if another forum is more appropriate.

In analyzing the forum non conveniens claim, the court emphasized that the burden of proof lies with the party seeking dismissal. The court found that Martim and his company failed to provide sufficient evidence to support their claims that arbitration in London would be an adequate alternative forum. The court noted that the allegations in the complaint did not establish that the parties were bound to submit to arbitration, nor did they demonstrate that the London forum would be appropriate.

Impact

This ruling has significant implications for both parties and the broader legal landscape in Florida. For Cattleya PTC, the court's decision allows the lawsuit to proceed in Florida, potentially leading to a resolution of the claims against Martim and his company. For Martim and MME Martim, LLC, the ruling underscores the challenges of enforcing arbitration agreements, particularly when the parties involved are not signatories to the contract.

The court's decision also serves as a reminder of the importance of providing adequate evidence when seeking to dismiss a case based on forum non conveniens. The ruling may set a precedent for future cases involving similar disputes, particularly in terms of the requirements for establishing jurisdiction and the enforceability of arbitration agreements.

What's Next

As the case continues, it remains to be seen whether Martim and his company will seek to appeal the court's decision further. There may also be related cases pending, but details were not available in the court filing. The outcome of this case could influence how similar disputes are handled in the future, particularly regarding arbitration and jurisdictional issues.