Federated Mutual Insurance Co. v. FedNat Holding Co.

FedNat, a Florida insurance company, appealed the district court's confirmation of an arbitration award in favor of Federal Mutual, a Minnesota insurance company. The Eighth Circuit vacated the district court's judgment and remanded with instructions to dismiss, holding that the district court lacked personal jurisdiction over FedNat.The court held that the district court lacked personal jurisdiction over FedNat, because it did not have the minimum contacts with Minnesota necessary for Minnesota to exercise jurisdiction under its long-arm statute. In this case, the choice-of-law provisions specifying that the forum state's laws govern were insufficient on their own to confer personal jurisdiction; the fact that the Co-Existence Agreement affected Federated Mutual in Minnesota did not subject FedNat to personal jurisdiction there; and the court's five-factor test showed that FedNat did not enter a contractual relationship that envisioned continuing and wide-reaching contacts in Minnesota. View "Federated Mutual Insurance Co. v. FedNat Holding Co." on Justia Law