The Relation Back Doctrine

The relation back doctrine set forth in Florida Rule of Civil Procedure 1.190(c) provides that an amended pleading relates back to the date of the original pleading when it arises “out of the conduct, transaction, or occurrence set forth or attempted to be set forth in the original pleading…” The rule allows amendments to relate […]

Lack of Personal Jurisdiction – Breach of Contract Action by Broker for Failure to Pay a Commission on Aircraft Sale

In Corporacion Aero Angeles, S.A. v. Fernandez, 69 So. 3d 295 (Fla. 4th DCA 2011), the plaintiff, Jamie Gaston Fernandez (“Fernandez”) brought an action for breach of contract arising out an oral brokerage agreement for the sale of a jet owned by Aero Angeles, a Mexican corporation (“Aero”).  Fernandez claimed that he was not paid […]