Carter v. Estate of Rambo, 925 So. 2d 353 (Fla. 5th DCA 2006)

Plaintiff sued the nursing home, its owner (an LLC) and the individual manger of the LLC. The manager was not a Florida resident and moved to dismiss the complaint on personal jurisdiction grounds. The manager contested each allegation that he was subject to jurisdiction in Florida, shifting the burden back to the Plaintiff. The Plaintiff attempted to meet this burden by showing that the manager had signed uniform business reports on behalf of the company. Applying the corporate shield doctrine, the court held that actions of the manager on behalf of the LLC are exempt when consider whether the manager’s conduct supported long-arm jurisdiction. Plaintiff presented no evidence that the manager personally committed any torts in Florida and the deposition testimony indicated that his only contact with Florida was signing the business reports as managing member of the LLC. The court erred by denying his motion to dismiss.