The personal representative of the resident’s estate sued multiple corporations for nursing home negligence including Residence Healthcare, a foreign corporation. Residence Healthcare moved to dismiss for lack of personal jurisdiction. Plaintiff is first required to demonstrate that the long-arm statute reaches the defendant; if so, then the court determines whether minimum contacts exist. In this case, the issue of minimum contacts was not reached because Plaintiff did not establish that the long-arm statute provided a basis for jurisdiction. Although Plaintiff alleged that Residence Healthcare established, conducted, managed, operated, or maintained the nursing home, and therefore had a duty to the resident that was breached, the court found that deposition testimony showed otherwise. The depositions also failed to show, other than ownership of a subsidiary, that Residence Healthcare conducted business in Florida or had any substantial activity in Florida. Ownership of a subsidiary, without more, is insufficient to confer jurisdiction and reversed. The court, however, note that if a parent corporation was shown to exercise sufficient control over a subsidiary, that control would establish agency and support jurisdiction. Here, the trial court was directed to grant the motion to dismiss.
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