Skip to Content

Florida Federal Court Grants Motion to Dismiss Petition to Confirm Arbitration Award, Finding Lack of Personal Jurisdiction
March 24, 2026

In Worldwide Aircraft Services Inc. v. Anthem Insurance Companies Inc., the U.S. District Court for the Middle District of Florida addressed a motion to dismiss filed on behalf of defendant Anthem BCBS to dismiss a petition to confirm an arbitration award based on several grounds, including lack of personal jurisdiction. 

Jet ICU, located in Tampa, provided emergency air ambulance services to an individual insured by Anthem BCBS and filed a claim with BCBS Federal Program Overseas Claims for the services it provided. A billing dispute arose regarding the proper payment amount and Jet ICU filed an arbitration or independent dispute resolution proceeding against BCBS Federal Program Overseas Claims under the No Surprises Act, 42 U.S.C. § 300gg-112. After the arbitrator determined the appropriate payment due for the services and entered an award for Jet ICU, Jet ICU filed a petition to confirm arbitration award naming Anthem BCBS as the respondent. Anthem BCBS then filed a motion to dismiss the petition arguing, among other points, a lack of personal jurisdiction. In support of its contention that the court lacked personal jurisdiction over it, Anthem BCBS submitted a declaration “negating the existence of any substantial connection … to Florida” including that Anthem BCBS is an Indiana corporation with a principal place of business in Indiana, does not fund or administer claims in Florida, does not maintain an office or phone contact in Florida, and does not advertise or solicit business in Florida.

The court found that the evidence submitted by Jet ICU in opposition to Anthem BCBS’ jurisdictional arguments did not establish personal jurisdiction over Anthem. Noting that due process requires that a defendant “by its own actions create the required minimum contacts with the forum state,” the court found that Jet ICU’s petition to confirm the arbitration award did not provide sufficient evidence to support the assertion of personal jurisdiction over Anthem BCBS under Florida’s long-arm statute or the due process clause of the U.S. Constitution. The court granted Anthem BCBS’ motion and dismissed the petition without prejudice.

Worldwide Aircraft Services, Inc. v. Anthem Insurance Companies, Inc., No. 8: 25-cv-01444 (M.D. Fla. Dec. 31, 2025).

 
Authored By
Image: Kenneth J. Cesta
Kenneth J. Cesta
Related Practices
Reinsurance
©2026 Carlton Fields, P.A. Carlton Fields practices law in California through Carlton Fields, LLP. Carlton Fields publications should not be construed as legal advice on any specific facts or circumstances. The contents are intended for general information and educational purposes only, and should not be relied on as if it were advice about a particular fact situation. The distribution of this publication is not intended to create, and receipt of it does not constitute, an attorney-client relationship with Carlton Fields. This publication may not be quoted or referred to in any other publication or proceeding without the prior written consent of the firm, to be given or withheld at our discretion. To request reprint permission for any of our publications, please use our Contact Us form via the link below. The views set forth herein are the personal views of the author and do not necessarily reflect those of the firm. This site may contain hypertext links to information created and maintained by other entities. Carlton Fields does not control or guarantee the accuracy or completeness of this outside information, nor is the inclusion of a link to be intended as an endorsement of those outside sites.

Disclaimer

The information on this website is presented as a service for our clients and Internet users and is not intended to be legal advice, nor should you consider it as such. Although we welcome your inquiries, please keep in mind that merely contacting us will not establish an attorney-client relationship between us. Consequently, you should not convey any confidential information to us until a formal attorney-client relationship has been established. Please remember that electronic correspondence on the internet is not secure and that you should not include sensitive or confidential information in messages. With that in mind, we look forward to hearing from you.