Kaminsky v. Hecht
Kaminsky v. Hecht, 272 So.3d 786 (Fla. 4th DCA 2019)
Does the Florida long-arm statute reach trustees of trusts administered elsewhere with beneficiaries in Florida? Committing a tortious act within the state is one of the enumerated acts which can give rise to jurisdiction for purposes of the long-arm statute. Fla. Stat. 48.193(1)a.2. While physical presence is not required to commit a tortious act for purposes of the long-arm statute, mere injury in Florida from a tortious act committed elsewhere is not enough.
Here, the Court found that the trustee of a trust who had never resided in Florida, had not administered the trust in Florida and did not hold trust assets in Florida, but may have failed to account to Florida beneficiaries or mismanaged trust assets for Florida beneficiaries did not meet the requirements of the long-arm statute for the Florida court to have jurisdiction over the trustee.