Daher Aerospace SA v. Blackford: A Key Ruling on Personal Jurisdiction in Florida Litigation

On June 4, 2025, the Florida Fourth District Court of Appeal issued a significant decision in Daher Aerospace SA v. Blackford, reversing a trial court’s ruling and dismissing a lawsuit against French aircraft manufacturer Daher Aerospace SA (“French Daher”) for lack of personal jurisdiction. This case, stemming from a 2019 plane crash in Michigan, clarifies the application of Florida’s long-arm statute and emphasizes the critical “connexity” requirement for establishing specific jurisdiction over non-resident defendants. For lawyers and business clients navigating jurisdictional issues, this ruling provides essential guidance on the limits of Florida’s jurisdictional reach across various types of litigation, from torts to commercial disputes.

Case Background

In 2003, Socata SA, the predecessor to French Daher, manufactured a TBM aircraft in France and sold it to Avex, Inc., a California-based distributor. The sales contract specified that delivery and title transfer occurred in France, with the aircraft insured by the seller for a ferry flight to Florida. There, Socata Aircraft, Inc., a Florida entity and predecessor to Daher Aircraft, Inc. (“Florida Daher”), inspected the aircraft before it was flown to California. No maintenance was performed in Florida at that time.

Eighteen years later, in 2019, the aircraft, then based in Muncie, Indiana, was chartered for a flight to Michigan. The passengers, none of whom were Florida residents, included Aaron Blackford, Zechariah Bennett, John Lowe, and Neil Sego. The plane crashed during landing in Michigan, killing all passengers except Blackford. The survivors and estates of the deceased filed lawsuits in Broward County, Florida, against French Daher, Florida Daher, Daher Aerospace, Inc., and Pratt & Whitney, alleging strict liability and negligence due to defective design and manufacture, which they claimed caused an engine failure.

French Daher moved to dismiss for lack of personal jurisdiction, arguing it did not conduct business in Florida and that the aircraft was designed, manufactured, and delivered in France. The plaintiffs asserted specific jurisdiction under section 48.193(1)(a)1., Florida Statutes (2021), which permits jurisdiction over a non-resident for a cause of action arising from operating a business in Florida. They cited French Daher’s ties with Florida Daher, including shared trademarks, interlocking officers, and Florida Daher’s role as an agent for U.S. sales and parts distribution.

Trial Court’s Ruling

Following an extensive evidentiary hearing, the trial court denied French Daher’s motion to dismiss. It found that French Daher conducted business in Florida through Florida Daher, which acted as its agent. The court noted that Florida Daher facilitated the 2003 aircraft sale by handling payment transfers and inspecting the aircraft in Florida. French Daher also advertised its U.S. headquarters in Pompano Beach, where Florida Daher operated, and supplied at least twenty replacement parts for the aircraft through Florida Daher. Additional Florida connections included sponsoring an annual airshow and partnering with a company for pilot training in Orlando.

The trial court concluded that these activities established a sufficient connection to Florida under section 48.193(1)(a)1., asserting that the plaintiffs’ claims arose from French Daher’s business operations in the state, either directly or through its agent, Florida Daher.

Appellate Court’s Decision

The Fourth District Court of Appeal reversed, holding that the plaintiffs failed to establish the necessary “connexity” between French Daher’s Florida activities and their claims. The court’s analysis focused on the two-pronged test for specific jurisdiction: (1) whether the claims fall within Florida’s long-arm statute, and (2) whether the defendant has sufficient minimum contacts with Florida to satisfy due process.

Long-Arm Statute and Connexity

Section 48.193(1)(a)1. requires that the cause of action “arise from” the defendant’s business activities in Florida, a requirement known as connexity. The plaintiffs’ claims centered on strict liability and negligence related to the aircraft’s design and manufacture, both of which occurred in France. The court found no direct nexus between these claims and French Daher’s Florida activities, such as the ferry flight, payment processing through Florida Daher, or marketing efforts like airshow sponsorships.

The court rejected the trial court’s finding that Florida Daher acted as French Daher’s agent for the aircraft’s delivery, noting that the sales contract explicitly stated delivery occurred in France. Even if delivery had occurred in Florida, it would not connect to the plaintiffs’ claims, which stemmed from the aircraft’s design and manufacture, not its sale or delivery. The provision of replacement parts through Florida Daher also lacked a clear link to the crash, as the record did not specify when or why these parts were supplied or their role in the accident.

Citing Hinkle v. Cirrus Design Corp. (11th Cir. 2019), the court emphasized that a defendant’s general business presence in Florida does not confer specific jurisdiction unless the plaintiff’s claims directly arise from those activities. In Hinkle, a Wisconsin manufacturer’s Florida contacts, including a sales representative and trade show appearances, were irrelevant to a crash-related claim because the purchase and crash occurred outside Florida. Similarly, French Daher’s Florida connections were tangential to the Michigan crash and the alleged defects.

Minimum Contacts and Due Process

The court also addressed the constitutional prong, referencing Bristol-Myers Squibb Co. v. Superior Court of California (2017), which rejected a “sliding scale” approach to specific jurisdiction. For jurisdiction to be constitutional, the defendant’s suit-related conduct must create a substantial connection with the forum state. French Daher’s activities, such as insuring the ferry flight or marketing in Florida, were not sufficiently tied to the plaintiffs’ claims to justify haling the company into a Florida court. The court stressed that Florida’s long-arm statute must be strictly construed, and the plaintiffs’ failure to show connexity was fatal to their jurisdictional argument.

Dissenting Opinion

Judge Artau dissented, arguing that the trial court’s findings supported both statutory and constitutional bases for jurisdiction. He contended that French Daher’s provision of technical assistance and replacement parts through Florida Daher, some installed in Florida, linked the company’s Florida activities to the plaintiffs’ claims. He also suggested general jurisdiction could apply, citing French Daher’s “continuous and systematic” affiliations with Florida, such as employing a Florida-based executive who oversaw global sales and signed FAA documents on French Daher’s behalf. The majority, however, noted the plaintiffs’ concession that they sought only specific, not general, jurisdiction.

Implications for Lawyers and Businesses

The Daher Aerospace decision reinforces the stringent requirements for establishing specific jurisdiction in Florida, with implications for a wide range of cases, including torts, commercial disputes, and contract claims. For attorneys, the ruling underscores the need to demonstrate a direct nexus between the defendant’s Florida activities and the cause of action. General business connections—such as marketing, affiliate relationships, or incidental activities like payment processing—are insufficient without evidence that the claims arose from those activities. This may lead plaintiffs to pursue claims in jurisdictions where the alleged wrongful conduct or harm occurred, as seen in the parallel tort actions filed in Michigan in this case.

For businesses, particularly foreign entities with U.S. affiliates, the case highlights strategies to minimize jurisdictional exposure. Clear contractual terms, such as specifying delivery outside Florida, can limit arguments for jurisdiction in interim locations. Companies should also carefully structure affiliate relationships to avoid imputing jurisdictional contacts, ensuring that entities like French Daher and Florida Daher maintain distinct operational boundaries. This is particularly relevant for businesses in industries like manufacturing, technology, or services, where cross-border operations and affiliate networks are common.

The ruling also serves as a reminder of the constitutional limits on jurisdiction. By aligning with Bristol-Myers Squibb, the court reaffirms that due process requires a substantial connection between the defendant’s forum activities and the litigation. This protects non-resident defendants from being drawn into Florida courts based solely on unrelated or minimal contacts, providing predictability for businesses operating across state or national lines.

Conclusion

The Daher Aerospace SA v. Blackford ruling clarifies the boundaries of Florida’s long-arm statute and the constitutional requirements for specific jurisdiction. By emphasizing the connexity requirement, the Fourth District Court of Appeal provides a framework for litigators and businesses to assess jurisdictional risks in Florida. As jurisdictional disputes remain a critical issue in complex litigation, this case offers valuable guidance for navigating the interplay between state statutes and due process across diverse legal contexts.