Case Explained: LUIS MANUEL RODRIGUEZ MARIA RODRIGUEZ v. IMPERIAL BRANDS, PLC CORPORACION HABANOS, S.A WPP, PLC YOUNG & RUBICAM, LLC BCW, LLC

Court: United States Court of Appeals for the Eleventh Circuit Filed: 2026-07-23 Docket: 1:20-cv-23287-DPG The Eleventh Circuit affirmed the district court’s dismissal of the plaintiffs’ complaint for lack of personal jurisdiction over British corporations WPP, PLC and Imperial Brands, PLC. The court held that while the Helms-Burton Act creates a private cause of action for trafficking in confiscated Cuban property, it does not expressly authorize nationwide service of process under Federal Rule of Civil Procedure 4(k)(1)(C). Consequently, the plaintiffs’ claims against these foreign defendants must be evaluated under Rule 4(k)(2), which requires that exercising jurisdiction be consistent with the Fifth Amendment’s Due Process Clause. Relying on the Supreme Court’s decision in *Fuld v. Palestine Liberation Organization*, 606 U.S. 1 (2025), the Eleventh Circuit determined that the Fifth Amendment does not incorporate the Fourteenth Amendment’s “minimum contacts” standard but instead imposes a flexible “reasonableness” inquiry. Applying this reasonableness test, which weighs the burden on the defendant, the interests of the forum state, and the plaintiff’s interest in obtaining relief, the court concluded that asserting jurisdiction over WPP and Imperial would be unreasonable. The court found that neither defendant received clear statutory notice under the Helms-Burton Act that they could be sued in U.S. courts, neither engaged in conduct with a meaningful connection to the United States, and neither maintained a significant presence in the country sufficient to justify the severe burden of litigating in Florida. Additionally, the court held that the actions of WPP’s U.S.-based subsidiaries could not be imputed to the parent company absent alter-ego status, which was not established. As a result of this decision, the plaintiffs’ claims against WPP and Imperial remain dismissed. The case is closed with respect to these defendants, and no further proceedings regarding personal jurisdiction over them will occur in the federal courts. Do It For The Case Law is a news reporting service. Nothing in this episode constitutes legal advice.