Mealey's ( April 29, 2021, 10:58 AM EDT) -- ATLANTA — A Florida district court must determine whether it had subject matter jurisdiction “in the first instance” before an appeal proceeds on its dismissal of Tim Hortons franchisees’ predatory business scheme claims against a franchisor, the 11th Circuit U.S. Court of Appeals said April 27, remanding the case upon finding a dispute about whether diversity jurisdiction existed because the association failed to allege its place of incorporation to establish diversity of citizenship....