PHYLLIS ZYSKIND
v.
ELENA KOSS, ETC.

Fla. 3d DCA | 2024-02-21
No. 2023-0424
2024 FL 1737 Florida District Court of Appeal, Third District (2024) Negative Treatment

AI-generated. These summaries, headnotes, and key points are machine-generated and may contain errors or omissions. Always verify against the full opinion text below. Not legal advice.


Holding

A nonresident corporate officer is subject to personal jurisdiction in Florida if the officer directed fraud or other intentional misconduct at parties in the State of Florida.


Headnotes

[1] A nonresident corporate officer may be subject to personal jurisdiction under Florida's long-arm statute if the officer directed fraud or other intentional misconduct at…

Previewing 1 of 1 headnotes on this case. FLexlaw’s editorially structured points of law — every proposition, pinpointed — are reserved for members.

Join FLexlaw to unlock all legal intelligence

Key Quotes

“A nonresident corporate officer is subject to personal jurisdiction if the officer directed 'fraud or other intentional misconduct' at parties in the State of Florida.”

Shwartzberg v. Knobloch, cited for the principal jurisdictional rule

Facts & Procedural History

Phyllis Zyskind and others appealed non-final orders from the Circuit Court for Miami-Dade County regarding jurisdiction over Elena Koss, a nonresiden…

The full statement of facts, procedural history, and disposition for this case are member content.

Join FLexlaw to unlock all legal intelligence

© FLexlaw, Inc. — AI-generated enrichments are proprietary. All rights reserved.


Opinion of the Court

PER CURIAM.

Affirmed. Shwartzberg v. Knobloch, 98 So. 3d 173, 181 (Fla. 2d DCA 2012) (“[A] nonresident corporate officer is subject to personal jurisdiction if the officer directed ‘fraud or other intentional misconduct’ at parties in the State of Florida.”) (citation omitted); see Walter Lorenz Surgical, Inc. v. Teague, 721 So. 2d 358, 359 (Fla. 1st DCA 1998) (“The court's sole inquiry and determination [is] whether the tort as alleged occurred in Florida, and not whether the alleged tort actually occurred.”); Amersham Enters., Inc. v. Hakim-Daccach, 333 So. 3d 289, 297 (Fla. 3d DCA 2022) (“Our Supreme Court has previously held that directing a conspiracy and tortious conduct toward Florida satisfies both specific long-arm jurisdiction and the due process concerns implicated in a minimum contacts analysis.”) (citing § 48.193(1)(a)(2), Fla. Stat.); see also NHB Advisors, Inc. v. Czyzyk, 95 So. 3d 444, 448 (Fla. 4th DCA 2012) (“[I]f a plaintiff has successfully alleged a cause of action for conspiracy among the defendants to commit tortious acts toward the plaintiff, and if the plaintiff has successfully alleged that any member of that conspiracy committed tortious acts in Florida in furtherance of that conspiracy, then all of the conspirators are subject to the jurisdiction of Florida through its long-arm statute.”).


Cases With Similar Vibessemantic neighbors from the corpus


Citator

Authorities Cited

Full citator, related cases, and AI research tools

Open in FLexlaw