Justia Florida Supreme Court Opinion Summaries

Valerie Audiffred and her husband, Robert Kimmons, filed an action against Thomas Arnold that arose from an automobile collision. A settlement proposal was filed on behalf of Audiffred, which Arnold constructively rejected. After a trial, a verdict was entered against Arnold for Audiffred’s past medical expenses. The jury did not award anything to Kimmons for his loss of consortium claim. Audiffred and Kimmons subsequently filed a motion seeking an award of attorney’s fees pursuant to Fla. Stat. 768.79 and Fla. R. Civ. P. 1.442. Arnold moved to strike the settlement proposal, arguing that it was defective because it did not apportion the settlement amount between Audiffred and Kimmons. The trial court denied the motion to strike and awarded attorney’s fees. The district court reversed the award of attorney’s fees, concluding that the settlement offer constituted a joint proposal and that the proposal was invalid for failing to comply with the statute and rule. The Supreme Court affirmed, holding that when a single offeror submits a settlement proposal to a single offeree pursuant to section 768.79 and rule 1.442 and the offer resolves pending claims by or against additional parties who are neither offerors nor offerees, it constitutes a joint proposal that is subject to the apportionment requirement of the rule. View "Audiffred v. Arnold" on Justia Law

Plaintiff filed suit against medical malpractice action against multiple defendants, including FMC Hospital, Ltd., d/b/a Florida Medical Center, and FMC Medical, Inc., d/b/a Florida Medical Center. A proposed settlement offer was served upon Plaintiff, but Plaintiff did not accept the offer. A jury subsequently returned a verdict adverse to Plaintiff, and the trial court entered final judgment in favor of Defendants. Thereafter, Defendants filed a motion for attorney’s fees and costs. Plaintiff opposed the motion, asserting that the entities were joint offerors and that the proposal was invalid because it failed to apportion the amount offered as required by Fla. Stat. 768.79 and Fla. R. Civ. P. 1.442. The trial court granted the motion, concluding that there was only a single offeror - Florida Medical Center - and therefore, apportionment of the amount offered was not required. The district court affirmed, concluding that because the offer was made on behalf of the single hospital entity allegedly responsible for Plaintiff’s injury, the settlement proposal complied with the statute and rule. The Supreme Court quashed the district court’s decision, holding that the offer constituted a joint proposal and, under a strict construction of section 768.79 and rule 1.442, apportionment of the settlement amount was required. View "Pratt v. Weiss" on Justia Law

After a jury trial, Defendant was found guilty of second-degree murder, among other offenses. Defendant was received a sentence of life imprisonment for the murder conviction. On appeal, Defendant argued that the trial court erred by refusing to allow defense witness Angela Tyler to testify about Ray Allen Brown’s out-of-court statement and in prohibiting Defendant from questioning Brown about the purported statements he made to Tyler. The district court affirmed. Defendant appealed, arguing, inter alia, that the trial court erred (1) when it infringed upon the jury’s role by determining that Tyler's testimony was not credible, and (2) in evaluating the corroboration factor of the Chambers v. Mississippi analysis because it rejected Defendant’s own statement to detectives as adequate corroboration of Brown’s alleged confession. The Supreme Court quashed the district court’s decision, holding (1) the trial court improperly evaluated the credibility of Tyler’s testimony and erred when it excluded her testimony on that basis; and (2) a defendant’s own statement may be considered as corroboration of a witness’ testimony for the purpose of the corroboration factor of the Chambers analysis. View "Bearden v. State" on Justia Law

Defendant was indicted on charges of first-degree murder and robbery with a weapon and pled guilty to both counts. At the conclusion of the penalty phase, the jury returned a unanimous recommendation of death. The trial court sentenced Defendant to death. The Supreme Court affirmed the convictions and sentences. Defendant later filed a motion to vacate the judgment of conviction under Fla. R. Crim. P. 3.851, alleging that he had received ineffective assistance of counsel. The postconviction court denied relief. The Supreme Court affirmed, holding that Defendant failed to demonstrate ineffective assistance of counsel as to any of his claims. View "Guardado v. State" on Justia Law

The Florida Judicial Qualifications Commission (JQC) recommended that Jessica J. Recksiedler, Eighteenth Judicial Circuit Court Judge, receive the sanction of a public reprimand for violating Canons 1, 2A, 4A(2), and 4A(3) of the Florida Code of Judicial Conduct. The disciplinary action stemmed from the answers Judge Recksiedler gave to questions regarding her driving record. Judge Recksiedler did not contest the JQC’s finding that her conduct violated the Code of Judicial Conduct, agreed to the recommended discipline, and entered into a stipulation. The Supreme Court approved the stipulation as well as the JQC’s findings of fact as to all four violations of the Code of Judicial Conduct. The Court then approved the recommended discipline of a public reprimand. View "Inquiry Concerning Judge Recksiedler" on Justia Law

In this case, the Third District Court of Appeal read Graham v. Florida as creating a homicide-case exception to the categorical rule against sentencing a juvenile offender to life without parole for a nonhomicide crime. The court’s reading would permit a juvenile to be sentenced to life without parole for a nonhomicide offense if the juvenile also committed a homicide in the same criminal episode. Applying this homicide-case exception, the Third District held that Defendant’s life-without-parole sentences for certain nonhomicide offenses committed as a juvenile were constitutional under Graham because Defendant also committed a homicide in the same criminal episode. The Supreme Court quashed the Third District’s decision, holding that Graham’s categorical rule leaves no room for the homicide-case exception recognized by the state’s Second, Third, and Fourth District Courts of Appeal. Remanded with instructions that Lawton be resentenced for the nonhomicide offenses of attempted first-degree murder with a firearm and armed robbery with a firearm. View "Lawton v. State" on Justia Law

Fifteen-year-old Abel Limones suddenly collapsed during a high school soccer game from a previously undetected underlying heart condition. Twenty-six minutes after Abel’s initial collapse, emergency responders revived him. Abel survived but suffered a severe brain injury due to a lack of oxygen over the time delay involved. Abel’s parents (Petitioners) filed this action against the School Board of Lee County (Respondent) alleging that Respondent breached both a common law and a statutory duty when it failed to apply an automated external defibrillator on Abel after his collapse. The trial court granted summary judgment for Respondent. The Second District Court of Appeal affirmed. The Supreme Court quashed the decision below and remanded for trial, holding that Respondent owed a common law duty to supervise Abel, and once Abel was injured, Respondent owed a duty to take reasonable measures and come to his aid to prevent aggravation of his injury. View "Limones v. Sch. Dist. of Lee County" on Justia Law

As surviving spouse of Stuart Hess and personal representative of his estate, Plaintiff filed a lawsuit against Philip Morris USA (Defendant), asserting claims of fraudulent concealment and alleging that Mr. Hess detrimentally relied on and dried as a proximate result of Defendants’ fraud. A jury entered judgment in favor of Plaintiff and awarded both compensatory and punitive damages. Defendant moved for judgment as a matter of law on the fraudulent concealment claim, arguing that it did not defraud Mr. Hess within the twelve-year fraud statute of repose period. The trial court denied the motion. The Fourth District Court of Appeal reversed for entry of judgment in Defendant’s favor on the fraudulent concealment claim and punitive damages award, concluding that the fraudulent concealment claim and punitive damages award were foreclosed by the statute of repose because Defendant did not defraud Mr. Hess within the repose period. The Supreme Court quashed the Fourth District’s decision and reinstated the jury verdict, holding that Defendant was precluded as a matter of law from raising the fraud statute of repose defense to Plaintiff’s fraudulent concealment claim. View "Hess v. Philip Morris USA, Inc." on Justia Law

Plaintiff filed a complaint against Philip Morris USA, Inc. and R.J. Reynolds Tobacco Company (together, Defendants) alleging that her smoking of Defendants’ cigarettes proximately caused her to develop chronic obstructive pulmonary disease. A jury found that Plaintiff’s claims were barred by the applicable four-year statutes of limitations. The Third District Court of Appeal reversed, concluding that there was no competent record evidence that Plaintiff’s claims accrued before the statute of limitations bar date. The Third District also denied Defendants’ arguments on cross-appeal, including the assertion that Plaintiff’s fraudulent concealment and conspiracy to conceal claims were barred by the fraud statute of repose. The Supreme Court approved the Third District’s decision to the extent of its conclusion concerning the statute of repose and disapproved two decisions of the Fourth District Court of Appeal that expressly and directly conflicted with the decision in this case, holding (1) the plain language of the fraud statute of repose does not require proof of reliance on an act committed no more than twelve years before the complaint was filed; and (2) the trial court did not err in denying Defendants’ requested jury instruction on the statute. View "Philip Morris USA, Inc. v. Russo" on Justia Law

Clipper Bay Investments, LLC filed an action to quiet title and ejectment against the Florida Department of Transportation (FDOT) seeking to quiet title to a portion of land adjacent to an interstate in Santa Rosa County under the Marketable Record Title Act (MRTA). FDOT alleged that the land to which Clipper Bay claimed title was a portion of what FDOT considered part of its interstate right-of-way, and, as such, the property was exempt from the MRTA under the right-of-way exception in Fla. Stat. 712.03. The trial court quieted title in favor of Clipper Bay for a portion of FDOT’s estate but not the entire disputed area. The First District Court of Appeal reversed, finding that FDOT failed to present competent, substantial evidence that its right-of-way included the land claimed by Clipper Bay. The Supreme Court quashed the First District’s decision, holding (1) the exceptions provided under section 712.03 may apply to rights-of-way held in fee; and (2) because the plain language of the statute provides that use of any part of the estate shall exempt the whole, FDOT established its entitlement to the exemption provided in section 712.03(5) for its entire fee estate. Remanded. View "Fla. Dep’t of Transp. v. Clipper Bay Invs., LLC" on Justia Law