JOHNSON & JOHNSON, ET AL.
v.
MSP RECOVERY CLAIMS, SERIES LLC, ET AL.

Fla. 3d DCA | 2024-09-25
No. 2023-0834
Arzola, J., Scales, J., Lindsey, J., Miller, J.
Florida District Court of Appeal, Third District (2024)

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Holding

A defendant waives its objection to personal jurisdiction by filing other motions to dismiss before raising the jurisdictional defense, thereby consenting to jurisdiction.


Headnotes

[1] A defendant waives its objection to personal jurisdiction by filing any other motion to dismiss before raising the jurisdictional defense, as the jurisdictional objection…

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Key Quotes

“A defendant's objection to personal jurisdiction must be raised 'in the first step the defendant takes in the case' or it is waived.”

Court's statement of the controlling legal standard for waiver of personal jurisdiction objections

Facts & Procedural History

Johnson & Johnson and Ethicon, Inc. were sued by MSP Recovery Claims, Series LLC in Miami-Dade County Circuit Court. Appellants filed three motions to…

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Per_curiam
Per Curiam

Third District Court of Appeal

State of Florida

Opinion filed September 25, 2024. Not final until disposition of timely filed motion for rehearing.

No. 3D23-0834 Lower Tribunal No. 18-41830

Johnson & Johnson, et al., Appellants,

vs.

MSP Recovery Claims, Series LLC, et al., Appellees.

An Appeal from a non-final order from the Circuit Court for Miami-Dade County, Antonio Arzola, Judge.

Squire Patton Boggs (US) LLP, and Andrew R. Kruppa and Amanda

E. Preston, for appellants.

MSP Recovery Law Firm, and Aida M. Landa and Janpaul Portal, for appellees.

Before SCALES, LINDSEY and MILLER, JJ.

ON MOTION FOR WRITTEN OPINION

PER CURIAM.

We grant Appellants Johnson & Johnson and Ethicon, Inc.'s motion for a written opinion. We withdraw our prior opinion issued on August 14, 2024, and substitute this opinion in its stead.

Because Appellants waived personal jurisdiction, we need not address the substantive issues on appeal.1 A defendant's objection to personal jurisdiction must be raised "in the first step the defendant takes in the case” or it is waived. See Allstate Mortg. Sols. Transfer, Inc. v. Bank of Am., N.A., 338 So. 3d 985, 988 (Fla. 3d DCA 2022). Appellants filed three motions to dismiss before challenging personal jurisdiction. Therefore, Appellants have consented to jurisdiction in Florida. See Fla. R. Civ. P. 1.140(b) (“Every defense in law or fact to a claim for relief in a pleading must be asserted in the responsive pleading, if one is required, but the following defenses may be made by motion at the option of the pleader . . . (2) lack of jurisdiction over the person . . . . Any ground not stated must be deemed to be waived . . . .”).

Affirmed.

Footnotes
1 On appeal, Appellants also raised the following issues: whether the trial court was correct that MSP Recovery Claims, Series LLC v. Coloplast Corp., 353 So. 3d 705, 706 (Fla. 3d DCA 2023) is controlling and Appellants are subject to jurisdiction pursuant to section 48.193(1)(a)(1); whether Appellants were required to provide an affidavit when objecting to personal jurisdiction; and whether dismissal with prejudice was warranted.

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