UNITED STATES DISTRICT COURT

SOUTHERN DISTRICT OF FLORIDA

WEST PALM BEACH DIVISION

CASE NO.: 9:22-cv-81883- RAR

BRITTANY ROBERSON, REBECCA

FREEMAN, BIANCA VINAS, and 

TIFFANY KING, individually and on 

behalf of others similarly situated, 

Plaintiff,

v.

HEALTH CAREER INSTITUTE LLC (dba

HCI COLLEGE LLC and HCI ACQUISITION LLC),

and FLORIAN EDUCATION INVESTORS LLC,

Defendant (s).

/

DEFENDANT FLORIAN EDUCATION INVESTORS LLC MOTION TO DISMISS 

PLAINTIFFS’ COMPLAINT

FOR LACK OF PERSONAL JURISDICTION

Defendant, FLORIAN EDUCATION INVESTORS LLC (“Florian”), by and through its

undersigned counsel, and pursuant to Federal Rule of Civil Procedure 12(b)(2), files this Motion 

to Dismiss Plaintiffs’ Complaint against it for Lack of Personal Jurisdiction, and in support 

thereof state as follows:

I. INTRODUCTION

Plaintiffs filed a Complaint against Defendants, HEALTH CAREER INSTITUTE LLC 

(“HCI”) and FLORIAN, alleging nine different counts premised on the operation of HCI’s 

nursing program, its enrollment contracts and college catalogs, as well as the offering and 

collection on loans purportedly issued by HCI, including the allegation that these loans were 

offered in an allegedly discriminatory manner. See Complaint, D.E. 1. Specially, the complaint 

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alleges claims for violations of Florida’s Deceptive and Unfair Trade Practices Act (“FDUTPA”) 

Counts 1-4; Breach of Contract, Counts 5-6; Unjust Enrichment- Count 7; Violation of the Equal 

Credit Opportunity Act- Count 8; and Violation of the Civil Rights Act- Count 9. 

As alleged in the Complaint, Plaintiffs are individuals who were enrolled in an Associate 

of Science in Nursing program in HCI’s West Palm Beach campus (“RN program”). Underlying 

Plaintiffs’ complaint is the allegation that Plaintiffs entered into enrollment agreements which 

governed the obligations between HCI and Plaintiffs. The majority if not all of the allegations of 

the complaint are directed at actions taken by HCI with respect the Plaintiffs’ enrollment in the 

RN program. With respect to Florian, the complaint’s allegations are minimal and appear to be 

premised solely on imputed liability for the acts of HCI. 

. The entirety of Plaintiffs’ claims against Florian should be dismissed because there is no 

basis for a court in Florida to exercise personal jurisdiction over a nonresident of the State of 

Florida under the facts alleged. Plaintiffs have failed to allege sufficient material facts to 

establish personal jurisdiction over Florian, a nonresident of Florida, under any provision of the 

Florida long-arm statute. Moreover, Plaintiffs’ allegations are devoid of any facts to satisfy the 

due process requirements of the Fourteenth Amendment to the United States Constitution, and 

are also devoid of any facts which would establish sufficient minimum contacts with the State of 

Florida. As such, Plaintiffs’ complaint against Florian must be dismissed.

II. STATEMENT OF FACTS

A. Factual Allegations Surrounding Personal Jurisdiction

In its complaint Plaintiff alleges:

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Defendants are subject to personal jurisdiction in this Court 

because they are authorized to transact and do transact business in 

Florida and because they maintain registered agents for service of 

process in Florida. Furthermore, Defendants regularly do business 

and solicit business in Florida, engage in persistent course of 

conduct in Florida and derive substantial revenue from their 

business in Florida. 

The complaint alleges that Florian is a Delaware corporation with its principal place of 

business in Darien, Connecticut and that Florian is a managing member of Defendant HCI. [DE 

1, ¶23]. The complaint further alleges that Florian’s CEO is listed in its SEC filings as Steven 

W. Hart and that in its annual reports to the Board of Nursing, Florian has reported its owner to 

be “Steve Hart.” [DE 1, ¶30-31]. Plaintiffs’ Complaint further states that under “statement of 

legal control,” HCI’s college catalog identifies HCI as a subsidiary of Florian. [DE 1, ¶33]. 

MEMORANDUM OF LAW

Plaintiffs’ Complaint should be dismissed because this Court lacks both general and/or

specific personal jurisdiction over Florian, a non-resident corporation. As admitted in the 

complaint, Florian is a nonresident Limited Liability Company organized under the laws of 

Delaware with its principal place of business in Connecticut. As will be discussed, this Court 

does not have jurisdiction of Florian under the laws of Florida and, in any event, Florian has 

insufficient minimum contacts with the State of Florida to be haled into any forum within the 

State.

A. Legal Standard

Under Federal Rule of Civil Procedure 12(b)(2), a party may assert as a defense a court’s 

lack of personal jurisdiction through a motion. A court must “dismiss an action against a 

defendant over which it has no personal jurisdiction.” Smith v. Trans-Siberian Orchestra, 689 F. 

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Supp. 2d 1310, 1312 (M.D. Fla. 2010) (citing Posner v. Essex Ins. Co., 178 F.3d 1209, 1214 n.6 

(11th Cir. 1999)); see also Roca Labs, Inc. v. Boogie Media, LLC, No. 8:12-cv-2231-T-33EAJ, 

2013 WL 2025806, at *1 (M.D. Fla. May 14, 2013). In determining whether there are grounds 

for a motion to dismiss for lack of personal jurisdiction, a court must accept the facts in the 

plaintiff’s complaint as true. Cable/Home Communication Corp. v. Network Productions, Inc., 

902 F.2d 829, 855 (11th Cir. 1990). The plaintiff bears the burden of pleading sufficient material 

facts to form a basis for personal jurisdiction, after which the burden shifts to the defendant to 

challenge the plaintiff’s allegations by affidavits or other pleadings. Future Technology Today, 

Inc. v. OSF Healthcare Sys., 218 F.3d 1247, 1249 (11th Cir. 2000); Cable/Home Communication 

Corp., 902 F.2d at 855; see also L.O.T.I. Group Prods. v. Lund, 907 F. Supp. 1528, 1530 (S.D. 

Fla. 1995) (noting that a “plaintiff seeking to subject a nonresident defendant to jurisdiction of 

the court must do more than allege facts that show a possibility of jurisdiction” (emphasis in 

original)). If the defendant sufficiently challenges the plaintiff’s assertion, then the plaintiff must 

affirmatively support its jurisdictional allegations and may not merely rely upon the factual 

allegations set forth in the complaint. Prentice v. Prentice Colour, Inc., 779 F. Supp. 578, 586 

(M.D. Fla. 1991).

Courts in the Eleventh Circuit follow a two-step analysis when deciding whether personal 

jurisdiction exists over a non-resident defendant. See Sculptchair, Inc. v. Century Arts, Ltd., 94 

F.3d 623, 626 (11th Cir.1996). First, the court must determine whether the state's long-arm 

statute (in this case Florida) provides a basis for personal jurisdiction over the defendant. Id. 

Second, if the state's long-arm statute provides a basis for personal jurisdiction, the court must 

then determine whether “minimum contacts” exist to satisfy the Due Process Clause of the 

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Fourteenth Amendment such that “maintenance of the suit does not offend traditional notions of 

fair play and substantial justice” as set forth in International Shoe Co. v. Washington, 326 U.S. 

310, 316, 66 S.Ct. 154, 90 L.Ed. 95 (1945). Id. (citations omitted). See Crowe v. Paragon 

Relocation Res., Inc., 506 F. Supp. 2d 1113, 1118–19 (N.D. Fla. 2007); Backer Elecs., Inc. v. 

Pentar Sys., Inc., 219 F. Supp. 2d 1260, 1261 (M.D. Fla. 2002); Meterlogic, Inc. v. Copier Sols., 

Inc., 126 F. Supp. 2d 1346, 1352 (S.D. Fla. 2000); Venetian Salami Co. v. J.S. Parthenais, 554 

So. 2d 499 (Fla. 1989). Only if both prongs of the analysis are satisfied, may a federal court 

exercise personal jurisdiction over a nonresident defendant such as Florian. Robinson v. 

Fiarmarco & Bill, P.C., 74 F.3d 253, 256 (11th Cir. 1996). 

Where a nonresident defendant challenges and/or refutes a plaintiff’s allegations of 

personal jurisdiction, the plaintiff bears the burden of proving jurisdiction by affidavits, 

testimony, or other documents. L.O.T.I Group Prod., 907 F. Supp. at 1528 (quoting Voorhees v. 

Cilcorp, Inc., 837 F. Supp. 395, 398 (M.D. Fla. 1993)); see also Oldfield v. Pueblo De Bahia 

Lora, S.A., 558 F.3d 1210, 1217 (11th Cir. 2009) (“It goes without saying that, where the

defendant challenges the court’s exercise of jurisdiction over its person, the plaintiff bears the 

ultimate burden of establishing that personal jurisdiction is present.”). Mere reliance on the 

factual allegations in the Complaint and self-serving affidavits by a plaintiff are insufficient to 

make the requisite showing. Prentice v. Prentice Colour, Inc., 779 F. Supp. 578, 583 (M.D. Fla. 

1991) (holding that once the defendant has made a prima facie showing that the long-arm statute 

does not apply, “the plaintiff is required to substantiate the jurisdictional allegations in the 

complaint by affidavits or other competent proof, and not merely reiterate the factual allegations 

in the complaint”).

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B. Florida’s Long Arm Statute Does Not Reach Defendants.

The Florida long-arm statute provides two alternative bases for the exercise of personal 

jurisdiction: specific or general jurisdiction. See Fla. Stat. § 48.193; Helicopteros Nacionales de 

Colombia, S.A. v. Hall, 466 U.S. 408, 414 (1984); Pathman v. Grey Flannel Auctions, Inc., 741 

F. Supp. 2d 1318, 1322 (S.D. Fla. 2010); Custom Fab, Inc. v. Kirkland, No. 6:13–cv–1511–Orl–

31DAB, 2014 WL 260090, at *3–5 (M.D. Fla. Jan. 23, 2014). In other words, this Court may 

exercise jurisdiction over Defendants only if there is specific or personal jurisdiction pursuant to 

the provisions of Florida’s long-arm statute. “General jurisdiction arises from the defendant’s 

contacts with the forum that are not directly related to the cause of action being litigated, while 

specific jurisdiction is found on a party’s activities in the forum that are related to the cause of 

action in the complaint.” Stubbs v. Wyndham Nassau Resort & Crystal Palace Casino, 447 F.3d 

1357, 1361 n.3 (11th Cir. 2006) (citations omitted). Florida’s long-arm statute provides, in 

pertinent part:

(1)(a) A person, whether or not a citizen or resident of this 

state, who personally or through an agent does any of the acts 

enumerated in this subsection thereby submits himself or herself 

and, if he or she is a natural person, his or her personal 

representative to the jurisdiction of the courts of this state for any 

cause of action arising from any of the following acts:

1. Operating, conducting, engaging in, or carrying on a 

business or business venture in this state or having an office or 

agency in this state.

2. Committing a tortious act within this state.

* * *

6. Causing injury to persons or property within this state 

arising out of an act or omission by the defendant outside this state, 

if, at or about the time of the injury, either:

a. The defendant was engaged in solicitation or service 

activities within this state;

***

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7. Breaching a contract in this state by failing to perform 

acts required by the contract to be performed in this state.

* * *

(2) A defendant who is engaged in substantial and not 

isolated activity within this state, whether such activity is wholly 

interstate, intrastate, or otherwise, is subject to the jurisdiction of 

the courts of this state, whether or not the claim arises from that 

activity.

Section 48.193, Fla. Stat. 

Accordingly, Defendants may be subject to specific personal jurisdiction in Florida for 

causes of action that arise from, inter alia, their business activities in Florida, alleged tortious 

acts committed within Florida or tortious acts committed outside of Florida that caused injury 

within Florida if Defendants were engaged in certain activities within Florida at the time. Id.

§ 48.193(1)(a). Alternatively, Defendants may be subject to general personal jurisdiction in 

Florida if they engage in substantial (not isolated) activity in Florida. § 48.193(2). “Because the 

reach of Florida’s long arm statute is a question of Florida law, federal courts are required to 

construe the long arm statute as would the Florida Supreme Court.” Meterlogic, Inc., 126 F. 

Supp. 2d at 1352. Furthermore, “Florida’s long-arm statute is to be strictly construed.”

Sculptchair, Inc. v. Century Arts, Ltd., 94 F.3d 623, 627 (11th Cir. 1996). 

General personal jurisdiction is grounded on the defendant's substantial or “continuous 

and systematic” contacts with the forum, regardless of whether those contacts are related to the 

cause of action. See Prentice v. Prentice Colour, Inc., 779 F. Supp. 578, 583–84 (M.D. Fla. 

1991). On the other hand, specific personal jurisdiction is exercised when the suit arises out of or 

is related to a party's single or isolated contacts with the forum. Id. Florida's long arm statute 

requires more activities or contacts to confer personal jurisdiction over a foreign defendant than 

those demanded by the due process clause. Id.

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 Here, Plaintiffs have failed to articulate a specific basis for applying Florida’s long-arm 

statute, either under general or specific jurisdiction, to Florian and make no mention of the statue 

at all. Rather, by way of paragraph 23 of the complaint, Plaintiffs seem to allege specific 

jurisdiction based on (1)(a)1, based on the allegation of “transact[ing] business in Florida” and 

because they “transaction business in Florida” and “maintain registered agents for service of 

process in Florida.” 

As an initial matter, this allegation is improper as it indiscriminatingly lumps both 

Defendants together and fails to establish personal jurisdiction over each individual Defendant. 

See Flava Works, Inc. v. Roje on Holiday Inc., 1:10-CV-23834, 2012 WL 1535684, at *5 (S.D. 

Fla. May 1, 2012)( improper for Plaintiff to indiscriminately lumps all of Defendants together as 

it must establish personal jurisdiction over each individual defendant based on that defendant's 

activities in and contacts with Florida); see also Castillo v. Allegro Resort Mktg., 603 Fed. Appx. 

913, 916 (11th Cir. 2015)(conclusory allegations are insufficient to establish a prima facie case 

of jurisdiction).

In any event, it appears Plaintiff is trying to allege specific jurisdiction by way of the 

allegation of paragraph 23 of Complaint since. although it does not track the statutory language, 

it nonetheless seems to suggest specific jurisdiction under section 48.193 (1)(a)1, which provides 

specific jurisdiction arising from the “operating, conducting, engaging in, or carrying on a 

business venture in this state or having an office or agency in this state.” 

While Florian does not concede that such pro forma allegations are sufficient to establish

a prima facie case of general jurisdiction, Florian has attached the declaration of Steven W. Hart 

on its behalf, which completely refutes the complaint’s allegations of Florian transacting 

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business in Florida, soliciting business in Florida or having an office or agency in the state. [See 

Exhibit “A]. To the extent that the complaint can be construed as one alleging general 

jurisdiction under subsection 2 of the long arm statute, Mr. Hart’s declaration overcomes same. 

Moreover, because general jurisdiction is held to a “stricter standard,” than specific 

jurisdiction, Plaintiffs failure to prove the transaction of business in relation to specific 

jurisdiction necessarily means that they cannot prove general jurisdiction based on the same 

allegations. See Kadylak v. Royal Caribbean Cruise, Ltd., 14-24149-CIV, 2016 WL 7536430, at 

*2 (S.D. Fla. Feb. 24, 2016)(general jurisdiction requires a defendant must be “essentially at

home in the forum state). Thus, under well-established law, Plaintiffs now bear the burden of 

establishing personal jurisdiction by competent evidence. Florian respectfully submits that they 

cannot. 

Further, it cannot be emphasized enough that all the actions identified in the complaint 

were alleged to have been undertaken by HCI, not Florian. As the complaint recognizes, Florian 

and HCI are two separate corporate entities. Accordingly, should any act in the complaint be 

construed as one establishing jurisdiction, such acts only inure to HCI. To the extent Plaintiffs 

are attempting to establish jurisdiction based on some sort of agency relation between HCI and 

Florian, under allegations of Florian being a “managing member”, a parent company or joint 

participation by Steven Hart, it fails. Under Florida’s long arm statute, the relationship of parentsubsidiary alone is insufficient to confer personal jurisdiction over the foreign parent corporation 

in the forum in which the subsidiary acts. Consolidated Dev. Corp. v. Sherritt, Inc., 216 F.3d 

1286, 1293 (11th Cir.2000). It is well-settled in Florida that a company’s status as parent, 

“without more, is ineffective to establish long-arm jurisdiction.” See Lee-Bolton v. Koppers Inc., 

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1:10CV253/MCR/GRJ, 2013 WL 11522040, at *4 (N.D. Fla. Sept. 9, 2013); Enic, PLC v. F.F. 

South & Co., 870 So. 2d 888, 891 (Fla. 5th DCA 2004)(ownership of a resident subsidiary 

corporation by an out-of-state parent corporation, without more, has been repeatedly deemed 

insufficient to meet the requirements of section 48.193; see also Greystone Tribeca Acquisition, 

L.L.C. v. Ronstrom, 863 So. 2d 473, 476 (Fla. 2d DCA 2004) (holding that out-of-state parent 

corporation's resident subsidiary which was the owner, operator, and licensee of a nursing home 

located within the state did not constitute activity sufficient to grant personal jurisdiction over 

parent corporation, even though parent corporation was disclosed on state licensure filings); 

Capital One Fin. Corp. v. Miller, 709 So. 2d 639, 640 (Fla. 2d DCA 1998) (finding foreign 

holding company's ownership of subsidiary within the state insufficient to satisfy the long-arm 

statute); Walt Disney Co. v. Nelson, 677 So. 2d 400, 403 (Fla. 5th DCA 1996) (holding parent 

corporation's ownership of a subsidiary which conducted business in the state, without more, 

insufficient to establish long-arm jurisdiction); Qualley v. Int'l Air Serv. Co., 595 So. 2d 194, 196 

(Fla. 3d DCA 1992) (holding requirements of section 48.193 were not met for parent corporation 

which owned a subsidiary actively involved in business in Florida, even though parent 

corporation also performed certain accounting and payroll functions for its subsidiary). Likewise, 

Plaintiffs' allegations that Steve Hart was both a principal or director at both HCI and Florian, is 

alone insufficient to satisfy the long-arm statute. See Unitedhealthcare of Florida, Inc. v. Am. 

Renal Associates Holdings, Inc., 16-81180-CIV, 2017 WL 1832436, at *7 (S.D. Fla. May 8, 

2017)(overlap of board of directors and the officers of parent and subsidiary, does not destroy 

the parties’ legal identifies for jurisdictional purpose). 

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Jurisdiction can be exercised over the parent where “a parent corporation exerts such 

extensive operational control over a subsidiary that the subsidiary is no more than an agent 

existing to serve only the parent's needs.” Gadea v. Star Cruises, Ltd., 949 So. 2d 1143 (Fla. 3d 

DCA 2007). Operational control has also been referenced as the day-to-day control of the 

internal affairs or basic operations of the subsidiary. See Yellow Pages Photos, Inc. v. Ziplocal, 

LP, 8:12-CV-755-T-26TBM, 2012 WL 5830590, at *3–4 (M.D. Fla. Nov. 16, 2012); Enic, 870 

So. 2d at 891–92 (citing Kramer Motors, Inc. v. British Leyland, Ltd., 628 F.2d 1175 (9th Cir.), 

cert. denied, 449 U.S. 1062, 101 S.Ct. 785, 66 L.Ed.2d 604 (1980)). The amount of control 

exercised by the parent must be high and very significant.” Id.; citing Enic, 870 So. 2d at 891. 

What is required for jurisdiction based on agency is not some merely control but “operational 

control” by the parent over the subsidiary. State v. Am. Tobacco Co., 707 So. 2d 851, 856 (Fla. 

4th DCA 1998); see also Gen. Cigar Holdings, Inc. v. Altadis, S.A., 205 F. Supp. 2d 1335, 1344 

(S.D. Fla. 2002), aff'd sub nom. Gen. Cigar Holdings v. Altadis, S.A., 54 Fed. Appx. 492 (11th 

Cir. 2002)(plaintiff must show that the subsidiary is merely an agent through which the parent 

company conducts business, “or that the subsidiary's separate corporate status is formal only and 

without any semblance of individual identity). As long as the subsidiary maintains a 

“semblance” of independence from the parent, the agency relationship will not be established. 

Id. (emphasis added).

It appears that Plaintiffs are attempting to allege the required operational control by the 

conclusory allegation that Florian is a “managing member” of HCI. However, as discussed above 

such conclusory allegation is insufficient to confer personal jurisdiction by this Court over 

Florian. In addition, the declaration of Steven W. Hart, makes it clear that Florian has no 

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operation control over HCI and that it at least has a “semblance” of independence. Accordingly, 

Plaintiffs now have the burden to prove jurisdiction by competent evidence. Florian respectfully 

submits that they cannot. 

CONCLUSION 

For the foregoing reasons, FLORIAN EDUCATION INVESTORS LLC. respectfully 

requests that this Motion to Dismiss be granted, and that Plaintiff’s Complaint against it be 

dismissed for lack of personal jurisdiction.

By: KUBICKI DRAPER

110 East Broward Boulevard, Suite 1400

Ft. Lauderdale, Florida 33301

Direct Line: (954) 713-2323

MJC-KD@kubickidraper.com

BF-KD@kubickidraper.com

BY: /S/ Michael J. Carney

 MICHAEL J. CARNEY

Florida Bar No. 44326

BARBARA FOX

Florida Bar No. 155608

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CERTIFICATE OF SERVICE

I HEREBY CERTIFY that a true and correct copy of the foregoing has been furnished by 

through Florida’s e-filing portal this 31ST day of January 2023 to: Eric A. Schmidt Esq. 769 

Centre Street, Suite 166 Jamaica Plain, MA 02130, eschmidt@ppsl.org. Rebecca C. Eisenbrey 

Esq. 769 Centre Street, Suite 166 Jamaica Plain, MA 02130, reisenbrey@ppsl.org. Nicole Casey 

Mayer Esq. 769 Centre Street, Suite 166 Jamaica Plain, MA 02130, 

Nicole@mayerlawflorida.com.

By: KUBICKI DRAPER

110 East Broward Boulevard, Suite 1400

Ft. Lauderdale, Florida 33301

Direct Line: (954) 713-2323

MJC-KD@kubickidraper.com

BF-KD@kubickidraper.com

BY: /S/ Michael J. Carney

 MICHAEL J. CARNEY

Florida Bar No. 44326

BARBARA FOX

Florida Bar No. 155608

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