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Florida Fourth DCA reverses trial court's denial of defendant's motion to dismiss based on forum non conveniens, citing trial court's failure to conduct required analysis

On August 9, 2017, in Celebration Cruise Line v. Dobrianskiy, No. 4D17-514, the Florida Fourth DCA reversed a trial court’s denial of the defendant’s motion to dismiss on the grounds of forum non conveniens. The plaintiff, an employee of the defendant cruise line, had been injured while helping to transport a ship sold by the defendant to its new owner. The defendant cruise line had moved for dismissal based on forum non conveniens, arguing that Broward County was an inconvenient forum and that Florida had no nexus to the lawsuit. The trial court granted the defendant’s motion, but according to the Fourth DCA, the trial court did so without first conducting the multi-factor analysis required by Kinney System, Inc. v. Continental Ins. Co., 674 So. 2d 86 (Fla. 1996) and Fla. R. Civ. P. 1.061(a) (codifying the Kinney factors).