Swindell v. Florida East Coast Railway Co.
Plaintiff Edward LeRoy Swindell, a New York resident, sued Florida East Coast Railway for personal injuries due to asbestos exposure while working for the defendant in Florida between 1939 and 1952. The defendant, a Florida corporation with its headquarters in St. Augustine, Florida, moved to dismiss the action for lack of personal jurisdiction in New York. The court examined New York Civil Practice Law §§ 301 and 302, concluding that the defendant's contacts with New York did not constitute "doing business" or "transacting business" sufficiently related to the cause of action. The court also rejected the argument that the injury occurred in New York because emotional distress manifested there. Consequently, the defendant's motion to dismiss for lack of personal jurisdiction was granted, and the case was dismissed without prejudice to refiling in an appropriate forum.