Justia Florida Supreme Court Opinion Summaries

After Ereck Plancher, a University of Central Florida (UCF) football player, collapsed and died during football practice conditioning drills, Ereck’s parents (the Planchers) filed a negligence action against UCF and UCF Athletic’s Association, Inc. (UCFAA). A jury found UCFAA, the statutorily authorized direct-support organization responsible for administering UCF’s athletics department, liable and awarded the Planchers $10 million in damages. The Court of Appeal reversed, concluding that UCFAA was entitled to limited sovereign immunity. The Planchers appealed, arguing that UCF did not have sufficient control over UCFAA’s day-to-day operations to entitle UCFAA to limited sovereign immunity. The Supreme Court affirmed, holding that UCFAA was entitled to limited sovereign immunity under Fla. Stat. 768.28 because it primarily acts as an instrumentality of the state. Remanded for entry of a judgment corresponding to the jury’s award of damages but limiting UCFAA’s liability to $200,000. View "Plancher v. UCF Athletics Ass’n, Inc." on Justia Law

Plaintiff, joined by her husband, filed a lawsuit alleging that she suffered permanent injuries due to Defendant’s surgical malpractice. The jury returned a verdict for Plaintiff and awarded, along with economic damages, noneconomic damages for pain and suffering amounting to $1.45 million. Defendant moved to reduce the award of noneconomic damages to $500,000 pursuant to Fla. Stat. 766.118(2), which became effective after Plaintiff underwent the disputed surgical procedure. The trial court denied the motion, concluding that the statute was not retroactive. The Third District Court of Appeal reversed, holding that it was constitutionally permissible to retroactively apply section 766.118 because Plaintiff had no vested right to a particular damage award and thus suffered no due process violation. On remand, the trial court entered a judgment for Plaintiff based on the $500,000 statutory cap on noneconomic damages. The Third District affirmed. The Supreme Court quashed the Third District’s decision in Miles II, disapproved Miles I, and remanded with instructions that the original final judgment be reinstated, holding (1) the Court had jurisdiction to hear this appeal; and (2) generally, a litigant’s substantive and vested rights may not be infringed upon by the retroactive application of a substantive statute. View "Miles v. Weingrad" on Justia Law

After a condominium association (Association) prevailed in a breach of contract action against its insurance company (Insurer), it sued Insurer a second time, alleging a statutory first-party bad faith claim under Fla. Stat. 624.155. Insurer moved to dismiss the complaint, citing its immunity from suit under Fla. Stat. 627.351(6)(s). The trial court dismissed the complaint, concluding that a statutory bad faith action under section 624.155 was not among the specifically listed exceptions to the immunity provided in section 627.351(6)(s). The First District Court of Appeal reversed, determining that Insurer’s immunity did not extend to the “willful tort” of failing to attempt in good faith to settle claims as provided by section 624.155. The Supreme Court quashed the decision below, holding that a statutory first-party bad faith cause of action under section 624.155(1)(b) is not an exception to the immunity granted to Insurer by the Legislature. View "Citizens Prop. Ins. Corp. v. Perdido Sun Condo. Ass’n, Inc." on Justia Law

Appellant, an intellectually disabled man, was charged with sexual battery and, in 2004, was involuntarily admitted to nonsecure residential services under Fla. Stat. 393.11. In 2011, Appellant filed suit under 42 U.S.C. 1983 and 1988 in federal district court against the Director of the Agency for Persons with Disabilities, seeking a declaratory judgment that the state’s statutory scheme for involuntarily admitting intellectually disabled persons to residential services violates the due process clause of the Fourteenth Amendment because it does not provide people who have been involuntarily admitted to nonsecure residential services with periodic review of their continued confinement by someone with authority to release them. The district court granted the Agency’s motion for summary judgment, concluding that section 393.11 is constitutional. The Eleventh Circuit Court of Appeal certified questions of law to the Supreme Court concerning the issue. The Supreme Court answered (1) “support plan” review under section 393.0651 does not require the Agency to consider the propriety of a continued involuntary admission to residential services order entered under section 393.11; and (2) the Agency is not statutorily required to petition the circuit court for the release from an involuntary admission order in cases where the Agency determines that the circumstances that led to the initial admission have changed. View "J.R. v. Palmer" on Justia Law

The decedent in this case fell from a ladder, resulting in his death. Plaintiff sued the companies that manufactured and sold the ladder, alleging that Defendants were liable on the basis of strict liability and under negligence theories. The jury rendered a verdict finding Defendants liable. Neither party objected to the verdict. After the jury was discharged, Defendants moved to set aside the verdict, contending that the jury verdict was fundamentally inconsistent. The trial court denied the motion. The Third District Court of Appeal reversed, holding that the “fundamental nature” exception to the general rule that Defendants waived their challenges to the inconsistent verdict for failing to timely object applied in this case. The Supreme Court reversed, holding (1) a party must timely object to an inconsistent verdict under these circumstances or the issue is waived; and (2) because Defendants failed to timely raise their objection to the jury’s inconsistent verdict, the trial court did not err in denying Defendants’ motion to set aside the verdict. View "Coba v. Tricam Indus., Inc." on Justia Law

In 2013, the City of Cape Coral issued a special assessment to provide fire protection services. The City passed an ordinance levying a special assessment against all real property in the City, both developed and undeveloped. The City then filed a complaint to validate the debt. Eight property owners appeared in opposition to the special assessment. After a show cause hearing, the trial court entered its final judgment of validation. The Supreme Court affirmed the order of validation, holding that the City properly exercised its authority to issue a special assessment to fund fire protection services and that the assessment did not violate existing law. View "Morris v. City of Cape Coral" on Justia Law

After a retrial, Defendant was convicted of two counts of first-degree murder. The trial court sentenced Defendant to death for both murders. The Supreme Court affirmed the convictions and sentences on direct appeal. Defendant subsequently filed a seven-claim motion to vacate judgment of conditions and sentences and later amended his motion to add two additional claims. After an evidentiary hearing on some of the claims, the postconviction court denied all of Defendant’s claims. The Supreme Court affirmed the denial of postconviction relief and also denied Defendant’s petition for habeas corpus relief, holding (1) the postconviction court properly denied Defendant’s claims of ineffective assistance of counsel; (2) the postconviction court did not err in denying Defendant’s claim of newly discovered evidence; (3) Defendant waived his Brady claim; and (4) Defendant’s appellate counsel did not perform ineffectively. View "Brooks v. State" on Justia Law

After a jury trial, Appellant was convicted of two counts of first-degree murder. Appellant was sentenced to life in prison without the possibility of parole for one murder and to death for the second murder. The Supreme Court affirmed Appellant’s convictions and sentences, holding (1) the evidence was sufficient to support both of Appellant’s first-degree murder convictions; (2) the trial court did not err in its findings with respect to aggravating and mitigating circumstances; (3) the death penalty was proportionate in this case; and (4) Appellant’s claim that his death sentence was unconstitutional based on Ring v. Arizona was without merit under established Florida precedent. View "Hobart v. State" on Justia Law

After a jury trial, Appellant was sentenced to death for the murders of four individuals. The Supreme Court affirmed Appellant’s convictions and sentences. Appellant subsequently filed a motion for postconviction relief. The postconviction court denied relief after summarily denying several claims and holding an evidentiary hearing on Appellant’s claims of ineffective assistance of counsel. Appellant appealed the denial of his postconviction motion and petitioned the Supreme Court for a writ of habeas corpus. The Supreme Court affirmed the denial of Appellant’s postconviction motion and denied his habeas petition, holding (1) the trial court did not err in denying Appellant’s claims that trial counsel were ineffective during the guilt phase and the penalty phase; and (2) Appellant was not entitled to relief on his argument that Florida’s death penalty statute violates the Eighth Amendment’s standards of decency. View "Hunter v. State" on Justia Law

After a jury trial, Defendant was convicted of, among other crimes, first-degree felony murder for the murder of a police officer. Defendant was sentenced to death for the murder. Defendant raised three issues on appeal, his primary argument being that his death sentence was disproportionate. The Supreme Court affirmed the convictions but reversed Defendant’s sentence of death, holding that the death penalty was disproportionate under the facts presented here, as this was not one of the most aggravated and least mitigated of capital murders. Remanded to the trial court with directions to impose a life sentence. View "Delgado v. State" on Justia Law