Venetian Salami Co. v. Parthenais

J.S. Parthenais (plaintiff) owned a collections business in Florida. Venetian Salami Company (Venetian) (defendant), a Canadian corporation, contacted Parthenais about collecting a delinquent account-receivable. Parthenais ultimately sued Venetian in Florida for breach-of-contract, alleging that Venetian failed to pay for services performed. Parthenais claimed that Venetian contacted him in Florida about collecting on an account-receivable collectable in Florida, New York, and Canada, and that Venetian agreed to pay Parthenais in Florida. In contrast, Venetian claimed that it contacted Parthenais about a delinquent account collectible in New York, that all discussions about potentially engaging Parthenais’s services occurred in either New York or Canada, and that no payment agreement was ever reached. Parthenais claimed personal jurisdiction over Venetian, a nonresident corporation, under Florida’s long-arm statute. The trial court granted Venetian’s motion to dismiss for lack of jurisdiction, holding that Parthenais failed to establish that Venetian had the required minimum contacts with Florida to ground personal jurisdiction. Parthenais appealed. The appellate court reversed, holding that (1) jurisdiction over Venetian was proper under Florida’s long-arm statute; and (2) Parthenais did not need to establish minimum contacts in addition to satisfying the long-arm statute. Venetian appealed to the Florida Supreme Court.