Uffner v. La Reunion Francaise

Uffner's (plaintiff) yacht, insured by the defendants, sank off Puerto Rico's coast, and after the insurers denied his claim for lacking a current out-of-water survey, he sued for bad-faith denial in the District of Puerto Rico; the district court dismissed for improper venue, reasoning the contract claim's "triggering event" was the claim denial (unrelated to Puerto Rico), and separately for lack of personal jurisdiction, though the defendants had never objected to personal jurisdiction.