Background
Heather S. Maloney appealed a nonfinal order entered by the Circuit Court for Miami-Dade County in favor of A Better Blind, Inc. The Third District’s short per curiam opinion does not describe the underlying dispute or specify the precise ruling under review.
The court cited authorities addressing de novo review of legal rulings on personal jurisdiction and service, the need for an independent jurisdictional basis beyond a forum-selection clause, deference to trial-court fact findings based on live testimony, and the burden-shifting framework for jurisdictional affidavits.
The Court’s Holding
The Third District affirmed the nonfinal order.
The court gave no further application of the cited principles to the record and did not separately explain its reasoning. Its disposition leaves the circuit court’s order in place.
Key Takeaways
- The appealed nonfinal order was affirmed.
- Legal rulings concerning personal jurisdiction or service are reviewed de novo.
- Trial-court factual findings based on live testimony receive deference when supported by competent substantial evidence.
Why It Matters
The decision underscores that forum-selection language alone does not necessarily establish jurisdiction over a nonresident; an independent jurisdictional basis is required. It also highlights the importance of adequately supported jurisdictional affidavits and of the trial court’s factual findings in nonfinal jurisdictional appeals.