CATHERINE E. CZYZ
v.
PROGRESSIVE MICHIGAN INSURANCE COMPANY, ET AL.
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Catherine Czyz appealed a decision regarding personal jurisdiction over Progressive Michigan Insurance Company. The court affirmed, holding that the insurance contract and underlying risk were Michigan-based, negating Florida's long-arm statute jurisdiction and insufficient minimum contacts for federal due process.
The court affirmed the lower court's decision, holding that the jurisdictional facts negate the applicability of Florida's long-arm statute and that the foreign corporation lacked sufficient minimum contacts with Florida to satisfy federal constitutional due process requirements.
“Petitioner was a Michigan resident who contracted for automobile insurance with respondent, a Michigan insurance company. At the time this contract was entered into, both parties were located in Michigan, not Florida. The property covered under the policy and the risk insured against were likewise in Michigan, not Florida. These facts clearly negate the applicability of [section 48.193(1)(a)4., Fla. Stat.].”
Establishes that complete Michigan nexus defeats Florida long-arm statute jurisdiction
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Join FLexlaw to unlock all legal intelligenceCzyz, a Michigan resident, contracted for automobile insurance with Progressive Michigan Insurance Company, a Michigan insurance company. At the time …
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PER CURIAM.
Affirmed. See Meyer v. Auto Club Ins. Ass’n, 492 So. 2d 1314, 1315 (Fla. 1986) (“Petitioner was a Michigan resident who contracted for automobile insurance with respondent, a Michigan insurance company. At the time this contract was entered into, both parties were located in Michigan, not Florida. The property covered under the policy and the risk insured against were likewise in Michigan, not Florida. These facts clearly negate the applicability of [section 48.193(1)(a)4., Fla. Stat.].”); USAA Cas. Ins. Co. v. MSP Recovery Claims, Series LLC, Nos. 3D24-1056, 3D24-1316, 3D24- 1278, 2025 WL 3650282, at *5 (Fla. 3d DCA Dec. 17, 2025) (finding that where plaintiff did not "assert any breaches of Florida insurance contract claims,” they "did not connect their equitable claims to the insurers' alleged Florida activities”); Banco de los Trabajadores v. Cortez Moreno, 237 So. 3d 1127, 1132 (Fla. 3d DCA 2018) (“The court must first determine whether sufficient jurisdictional facts exist to bring the action within the ambit of Florida's long-arm statute (section 48.193), and then it must determine whether the foreign corporation possesses sufficient 'minimum contacts' with Florida to satisfy federal constitutional due process requirements.” (quoting Reynolds Am., Inc. v. Gero, 56 So. 3d 117, 119 (Fla. 3d DCA 2011)) (cleaned up)).
Cases With Similar Vibessemantic neighbors from the corpus
Citator
Authorities Cited
- Meyer v. Auto Club Ins. Ass'n, 492 So. 2d 1314 (Fla. 1986)
- Reynolds Am., Inc. v. Gero, 56 So. 3d 117 (Fla. 3d DCA 2011)