Justia Florida Supreme Court Opinion Summaries

Respondent Enterprise Leasing Company leased a motor vehicle to Elizabeth Price for less than a year. Her son crashed the leased vehicle into a vehicle owned by Petitioner Rafael Vargas. Vargas filed suit against Price and Enterprise. The only count of the complaint directed at Enterprise claimed that the company was vicariously liable as the owner of the vehicle, pursuant to state law section 324.021(9)(b)2. Vargas did not contend that Enterprise was negligent, that its lease to Price was improper, or that it was in any way at fault for the accident. Enterprise filed an Answer and affirmative defenses, asserting that pursuant to 49 U.S.C. §30106, or the "Graves Amendment," it had no liability. The circuit court granted Enterprise's motion for summary judgment, ruling that the Graves Amendment preempted state law, holding that the state law was a vicarious liability provision and not a financial responsibility one. The court entered a final judgment consistent with Enterprise's consent to judgment, and Vargas appealed. The appellate court affirmed the lower court's decision and held one issue for review by the Supreme Court: whether the Graves Amendment as enacted by Congress preempted state law involving short term leases of motor vehicles. Florida had eliminated vicarious liability for a certain category of owner/lessors; Congress, through the Graves Amendment, sought to eliminate vicarious liability for that category of owners/lessors in which the state law left exposed to liability. On analysis, the Supreme Court found that the savings clause of the Graves Amendment does not supersede state laws that impose financial responsibility on the owner of a vehicle or that impose liability on businesses who rent or lease vehicles for failure to meet financial responsibility requirements under state law, and affirmed the decision of the circuit court.

The Court considered whether a "sniff test" by a drug detection dog conducted at the front door of a private residence is a "search" under the Fourth Amendment, and if so, whether the evidentiary showing of wrongdoing that the government must make prior to conducting such a search is probable cause or reasonable suspicion. A Crimestoppers tip alerted police to a private home where drugs were suspected; officers arrived at the house with a drug detection dog. The dog alerted to the scent of marijuana, and on approaching the house, police then smelled the scent. The magistrate supressed the evidence seized at the home, and the State appealed. Petitioner Jardines sought review by the Court on a certified question that conflicted with state law pertaining to whether the "sniff test" was a violation of his constitutional rights. Concluding that the dog "sniff test" conducted here was an intrusive procedure because it took place in the home, the Court held that results of the "sniff test" were properly withheld from the magistrate's probable cause determination.