Smith v. Randall

The defendants below, Gregory Smith, et al., appeal from two non-final orders denying their motions to transfer venue to Pasco County based on improper venue and forum non conveniens. We reverse.

In Vance v. Minton, 444 So.2d 1162, 1164 (Fla. 3d DCA 1984), this court examined the venue statutes and concluded that the venue privilege attaches only when the action is “commenced.” In the instant case, as in all others, the cause of action commenced when the plaintiff filed her initial complaint in the Circuit Court for Dade County. Although the plaintiff subsequently filed an amended complaint,…