Actions for Declaratory Relief / Declaratory Judgment

Posted by David Adelstein on August 24, 2016
Trial Perspectives / Comments Off on Actions for Declaratory Relief / Declaratory Judgment

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Sometimes a party pursues what is known as an action for declaratory relief or declaratory judgment– for a trial court to declare their rights with respect to the application of a written document or instrument. In this manner, Florida Statute s. 86.021 states:

Any person claiming to be interested or who may be in doubt about his or her rights under a deed, will, contract, or other article, memorandum, or instrument in writing or whose rights, status, or other equitable or legal relations are affected by a statute, or any regulation made under statutory authority, or by municipal ordinance, contract, deed, will, franchise, or other article, memorandum, or instrument in writing may have determined any question of construction or validity arising under such statute, regulation, municipal ordinance, contract, deed, will, franchise, or other article, memorandum, or instrument in writing, or any part thereof, and obtain a declaration of rights, status, or other equitable or legal relations thereunder.

It has long been held that with respect to actions for declaratory relief:

Before any proceeding for declaratory relief should be entertained it should be clearly made to appear that there is a bona fide, actual, present practical need for the declaration; that the declaration should deal with a present, ascertained or ascertainable state of facts or present controversy as to a state of facts; that some immunity, power, privilege or right of the complaining party is dependent upon the facts or the law applicable to the facts; that there is some person or persons who have, or reasonably may have an actual, present, adverse and antagonistic interest in the subject matter, either in fact or law; that the antagonistic and adverse interests are all before the court by proper process or class representation and that the relief sought is not merely the giving of legal advice by the courts or the answer to questions propounded from curiosity.

Ahearn v. Mayo Clinic, 180 So.3d 165, 174 (Fla. 1st DCA 2015) quoting May v. Holley, 59 So.2d 636, 639 (Fla. 1952) (courts are not going to entertain hypothetical facts or facts that are contingent in nature to address the possibility of a legal injury).

Courts, however, are not going to render an advisory opinion about a future possibility of a legal injury because this means there is NOT a present injury at the time the declaration is being sought. See Apthorp v. Detzner, 162 So.3d 236 (Fla. 1st DCA 2015). Thus, it is imperative that there is a “bona fide, actual, present practical need for the declaration” dealing with the application of an actual fact pattern and these allegations should be included in the lawsuit seeking declaratory relief. See Ahearn, 180 So.3d at 174.

Generally, and subject so some exceptions, actions for declaratory relief must be filed in the trial court that has jurisdiction over that party’s monetary claims. For example, if you are moving for an action for declaratory relief in a civil matter where you are seeking in excess of $15,000 in damages, then the action for declaratory relief must be filed in a circuit court (since a circuit court has subject matter jurisdiction over matters in excess of $15,000). Conversely, if you are moving for an action for declaratory relief in a civil matter where you are seeking damages up to and including $15,000 in damages, then the action for declaratory relief must be filed in county court (since a county court has subject matter jurisdiction over matters up to and including $15,000 in damages).   This jurisdictional requirement is set forth in the following relevant language in Florida Statute s. 86.011:

The circuit and county courts have jurisdiction within their respective jurisdictional amounts to declare rights, status, and other equitable or legal relations whether or not further relief is or could be claimed. No action or procedure is open to objection on the ground that a declaratory judgment is demanded. The court’s declaration may be either affirmative or negative in form and effect and such declaration has the force and effect of a final judgment.

Please contact David Adelstein at dma@kirwinnorris.com or (954) 759-0026 or (407) 740-6600 if you have questions or would like more information regarding this article. You can also follow David Adelstein on Twitter @DavidAdelstein1.

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Foundation Required to Admit Prior Inconsistent Statement

Posted by David Adelstein on August 20, 2016
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One of the most effective impeachment vehicles to attack the credibility of a testifying witness is the prior inconsistent statement. A prior inconsistent statement is exactly what it seems – a statement previously made by the witness on a material issue that directly contradicts with what the witness is testifying to at trial.  The point of impeaching the witness with the prior inconsistent statement is to show the witness’ trial testimony is not credible—they are lying.   By attacking the credibility, you leave doubts in the trier of fact’s mind (e.g., jury) that the witness’ trial testimony needs to be discounted because of a material lie (either they were lying at trial or they were lying when they originally made the prior inconsistent statement).

However, the foundation needs to be properly laid in order to impeach the witness with the prior inconsistent statement.  

Section 90.614(2) of Florida’s Evidence Code provides in material part:

Extrinsic evidence of a prior inconsistent statement by a witness is inadmissible unless the witness is first afforded an opportunity to explain or deny the prior statement and the opposing party is afforded an opportunity to interrogate the witness on it, or the interests of justice otherwise require. If a witness denies making or does not distinctly admit making the prior inconsistent statement, extrinsic evidence of such statement is admissible.

If the witness admits making the prior inconsistent statement, then the matter is generally closed since the witness admitted the inconsistency. On the other hand, if the witness does not admit or recall making the prior inconsistent statement, then extrinsic evidence of the prior inconsistent statement is admissible to prove the witness made such statement. See MBL Life Assurance Corp. v. Saurez, 768 So.2d 1129, 1134 (Fla. 3d DCA 2000) (“When a witness states that she does not recall questions asked or answers given at a previous time, the law provides that extrinsic evidence of the prior statement is admissible.”).

For example, say a witness previously testified during a deposition that her company decided not to fulfill certain contractual obligations because it underestimated its bid and contract price and would have lost a tremendous amount of money if it fulfilled its contractual obligations. But, during trial, the same witness testified that her company did not perform under the contract because the other side refused to timely pay a certain amount of money. This is a material contradiction.   During cross-examination, the opposing lawyer is very interested in attacking that witness’ credibility with the earlier statement made during deposition.   How does the opposing lawyer lay a foundation?

First, the opposing lawyer will ask the witness if she remembers being deposed (on “X” date by “Y” person) where she was asked the following question and where she answered “that her company did not perform because it underestimated its bid and would have lost tons of money.” If the witness admits to making the prior inconsistent statement, they have the opportunity to try to explain the inconsistency and the opposing lawyer can cross-examine the witness on the admitted inconsistency. However, if the witness denies making the statement or does not recall, then the foundation was laid to admit the prior inconsistent statement.

If the prior inconsistent statement is not reliable (unlike a statement in a deposition, affidavit, official public document, or other self-authenticating / reliable document) then it may be necessary to call as a witness a person that heard the prior inconsistent statement–depends on how the prior inconsistent statement was made and memorialized.  See, e.g., Pearce v. State, 880 So.2d 561, 568-570 (Fla. 2004) (when witness testified he did not recall making prior inconsistent statement after proper foundation was laid, trial court erred by not allowing counsel to immediately show videotape of witness making prior inconsistent statement); MBL Life Assurance Corp., 768 So.2d 1129 (trial court erred by not allowing witness’ prior inconsistent statement to Coast Guard contained in Coast Guard’s report to be admitted when witness testified she did not recall making prior statement);  Kiwanis Club of Little Havana, Inc. v. Kalafe, 723 So.2d 838 (Fla. 3d DCA 1998) (trial court erred in not allowing counsel to introduce periodical articles to impeach witness’ trial court testimony that contained statements contradictory to witness’ trial court testimony).

 

Please contact David Adelstein at dma@kirwinnorris.com or (954) 759-0026 or (407) 740-6600 if you have questions or would like more information regarding this article. You can also follow David Adelstein on Twitter @DavidAdelstein1.

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Leading Questions Forming Basis of Appeal

Posted by David Adelstein on August 07, 2016
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During a direct examination at trial, a party will always tiptoe on the fine line of asking the witness leading questions in order to elicit the desired testimony.  Leading questions, in most circumstances, are objectionable during direct examination because it allows the lawyer asking questions to basically testify while leading the witness to the answer he or she is seeking.   Look, a lawyer will ask leading questions if he/she can get away with it—until the trial court sustains objections.  But, just because a trial court sustains an objection does not necessarily mean the lawyer will stop asking leading questions during direct examination.  If a lawyer can get away with leading a witness during direct examination to elicit the testimony needed, the lawyer will do so and probably should do so. 

When do leading questions in a civil trial become so over-the-top to warrant a new trial? They really do not! “[L]eading questions do not result in an error that will warrant a new trial.” Moore v. Gillet, 96 So.3d 933, 944 (Fla. 2d DCA 2012).

In Moore, during the defense, direct examination of a treating doctor was being conducted. The doctor was serving as a defense witness. The trial court sustained numerous objections that the defense was leading the defense witness. At some point, and despite there not being an objection or motion for mistrial by the plaintiff, the trial court terminated the defense’s questions of its witness due to the persistent leading questions.

At the conclusion of the trial, the trial court ordered a new trial upon motion by the plaintiff. One of the reasons the trial court granted the new trial was due to the defense’s persistent leading questions. The defense appealed the trial court granting a mistrial.

With respect to leading questions, the appellate court held that the issue was not properly preserved for appeal because the plaintiff did not move for a mistrial at the time of the questions. The trial court ceasing the defense’s examination of a defense witness due to leading questions was a severe remedy that the plaintiff agreed to. The plaintiff did not make a contemporaneous motion for mistrial based on the leading questions, but rather, accepted the trial court terminating the defense’s direct examination.   But, even if the plaintiff did contemporaneously move for a mistrial, the leading questions would not warrant a new trial because leading questions generally do not form the basis of error for purposes of an appeal.

 

Please contact David Adelstein at dma@kirwinnorris.com or (954) 759-0026 or (407) 740-6600 if you have questions or would like more information regarding this article. You can also follow David Adelstein on Twitter @DavidAdelstein1.

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Avoiding the Mistrial

Posted by David Adelstein on July 27, 2016
Trial Perspectives / Comments Off on Avoiding the Mistrial

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If you prevailed at trial, there is nothing worse than a mistrial. Talking about taking the wind out of your sails. It happens. Unfortunately.

Boyles, Personal Representative vs. Dillard’s Inc., 41 Fla.L.Weekly D1709a (Fla. 1st DCA 2016), is a case where the defense prevailed, but on appeal, the court granted a mistrial for multiple (or cumulative) reasons, only two of which will be discussed below. Both reasons, however, could have been avoided.

A. Closing Argument

 

First, during closing argument, the defense counsel tried to attack the credibility of the plaintiff’s trial testimony by bringing up what the plaintiff testified to during her deposition. The problem, however, was that the defense brought up the plaintiff’s deposition when the deposition transcript was NOT introduced into evidence or apparently used to impeach the plaintiff during her trial testimony. The defense only brought this up during closing in order to insinuate that the plaintiff was not telling the truth based on deposition testimony that was NOT in the record. This is a huge no-no! The appellate court expressed:

[B]ecause the inadmissibility of appeal to non-record evidence during closing arguments is such a fundamental and longstanding canon of trial practice and ethics, codified in rule 4-3.4 of the Rules Regulating the Florida Bar, defense counsel’s violation, if not intentional, was at least grossly reckless, particularly because it was committed during closing arguments, when such improper statements are especially likely to inflame the minds and passions of the jurors so that their verdict reflects an emotional response . . . rather than the logical analysis of the evidence in light of the applicable law.

Boyles, supra (internal quotations omitted).

B. Voir Dire

 

Second, and another basis for a mistrial, during voir dire, the plaintiff read a standard jury instruction to the venire (jury pool) and essentially asked whether anyone would have a problem applying the law. The defense objected and the trial court precluded the plaintiff from asking a potential juror about the jury instruction.   The appellate disagreed: “[D]enial to counsel of the opportunity to question prospective jurors on their ability to follow the law constitutes abuse of discretion and is grounds for a new trial.Boyles, supra (internal quotations and citations omitted).

 

Please contact David Adelstein at dma@kirwinnorris.com or (954) 759-0026 or (407) 740-6600 if you have questions or would like more information regarding this article. You can also follow David Adelstein on Twitter @DavidAdelstein1.

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Appealing Trial Court’s Interpretation of Contract

Posted by David Adelstein on July 24, 2016
Appeal, Standard of Review / Comments Off on Appealing Trial Court’s Interpretation of Contract

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Many disputes turn on the interpretation of a contract, contractual term, or written document. When the trial court rules on the interpretation, there will typically be a party that disagrees with the court’s interpretation. In these instances, this party will appeal the trial court’s interpretation. There is a value to appeal because the appellate standard of review is de novo meaning the appellate court will review the trial court’s record anew without giving deference to the trial court’s interpretation.

The interpretation of a written contract is a question of law and the appellate court construes the contract under a de novo standard of review. Notably, construction of contractual terms is a question of law, which we review de novo, provided that the language is clear and unambiguous and free of conflicting inferences.

Ciklin Lubetz Martens & O’Connell v. Patrick J. Casey, P.A., 41 Fla.L.Weekly D1678b (Fla. 4th DCA 2016 (internal quotations and citations omitted).

For example, in a dispute concerning a law firm’s partnership agreement as it pertains to the withdrawal of a partner, the trial court made an interpretation of the partnership agreement that resulted in certain amounts being awarded to the withdrawing partner. The law firm appealed the trial court’s interpretation and the appellate court, examining the partnership agreement under a de novo standard of appellate review, reversed certain interpretations by the trial court. This is because the appellate court was able to examine the partnership agreement anew without providing any deference to how the trial court interpreted the partnership agreement.

 

Please contact David Adelstein at dma@kirwinnorris.com or (954) 759-0026 or (407) 740-6600 if you have questions or would like more information regarding this article. You can also follow David Adelstein on Twitter @DavidAdelstein1.

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Illegality of Contract as Affirmative Defense

Posted by David Adelstein on July 16, 2016
Trial Perspectives / Comments Off on Illegality of Contract as Affirmative Defense

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There is an affirmative defense known as “illegality of contract.”   Under this defense, the defendant is claiming that performance under its contract became illegal to perform; thus, the defendant should be excused from further performance. Just like any affirmative defense, the burden is on the defendant to prove the illegality of contract. See Novak v. Gray, 469 Fed. Appx. 811, 813-14 (11th Cir. 2012) (defendant has burden of proving defense of illegality of contract).

An example of the application of this defense can be found in the dispute between a commercial landlord and its tenant in Lucas Games, Inc. v. Morris Associates, LLC, 2016 WL 3745372 (Fla. 4th DCA 2016). The facts of this case are discussed here, but the case concerned an issue where the tenant’s business became illegal to perform due to an amendment to Florida law. As a result, the tenant stopped conducting business and vacated the leased premises. The appellate court agreed with the tenant because the subject matter of the lease became illegal to perform such that the lease could not be enforced against the tenant (and excused the tenant’s performance under the lease.)

When asserting an affirmative defense at trial, remember, whether the defense is illegality of contract or another defense, the burden is on the defendant (party asserting defense) to prove it.  

Please contact David Adelstein at dma@kirwinnorris.com or (954) 759-0026 or (407) 740-6600 if you have questions or would like more information regarding this article. You can also follow David Adelstein on Twitter @DavidAdelstein1.

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Asserting Punitive Damages (or Appealing the Decision to Allow for Punitive Damages)

Posted by David Adelstein on July 09, 2016
Appeal, Standard of Review, Trial Perspectives / Comments Off on Asserting Punitive Damages (or Appealing the Decision to Allow for Punitive Damages)

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So, you are interested in pursuing punitive damages. Then you MUST comply with the requirements of Florida Statute s. 768.72. This statute provides in relevant part:

(1) In any civil action, no claim for punitive damages shall be permitted unless there is a reasonable showing by evidence in the record or proffered by the claimant which would provide a reasonable basis for recovery of such damages. The claimant may move to amend her or his complaint to assert a claim for punitive damages as allowed by the rules of civil procedure. The rules of civil procedure shall be liberally construed so as to allow the claimant discovery of evidence which appears reasonably calculated to lead to admissible evidence on the issue of punitive damages. No discovery of financial worth shall proceed until after the pleading concerning punitive damages is permitted.

(2) A defendant may be held liable for punitive damages only if the trier of fact, based on clear and convincing evidence, finds that the defendant was personally guilty of intentional misconduct or gross negligence. As used in this section, the term:

(a) “Intentional misconduct” means that the defendant had actual knowledge of the wrongfulness of the conduct and the high probability that injury or damage to the claimant would result and, despite that knowledge, intentionally pursued that course of conduct, resulting in injury or damage.

(b) “Gross negligence” means that the defendant’s conduct was so reckless or wanting in care that it constituted a conscious disregard or indifference to the life, safety, or rights of persons exposed to such conduct.

It is NOT appropriate to merely plead punitive damages in your initial lawsuit and think by virtue of this allegation that you will be able to argue punitive damages to the jury. That would not be fair, would it? This would simply allow a party in every civil lawsuit to argue punitive damages to the jury. 

Rather, and as you can see from the statute, you must reasonably show by proffering evidence to the trial court that you have a reasonable basis to the recovery of such damages. But, you are able to take discovery relating to evidence you want to proffer associated with punitive damages (assuming the discovery is reasonable).   And, presuming the trial court allows you to argue punitive damages to the jury, a defendant should only be liable for punitive damages based on clear and convincing evidence that the defendant was guilty of intentional misconduct or gross negligence, as defined in the statute.  The statute provides standards in order for a party to pursue and argue punitive damages to the jury.

What do you do if you are a defendant and the trial court grants the plaintiff’s motion for leave to include a punitive damages component? Punitive damages are a damages-component you do NOT want argued to the jury.

Certiorari review is available to determine whether a trial court has complied with the procedural requirements of section 768.72, but not to review the sufficiency of the [proffered] evidence.” HCA Health Services of Florida, Inc. d/b/a St. Lucie Medical Center v. Byers-McPheeters, 2016 WL 3549595, *1 (Fla. 4th DCA 2016).  Stated differently, you can seek a writ of certiorari arguing the trial court failed to properly comply with s. 768.72, but not to review the evidence proffered to the trial court relating to the trial court’s decision to allow a punitive damages component.

Please contact David Adelstein at dma@kirwinnorris.com or (954) 759-0026 or (407) 740-6600 if you have questions or would like more information regarding this article. You can also follow David Adelstein on Twitter @DavidAdelstein1.

 

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Just Say NO! to Frivolous Claims! Otherwise 57.105 May Apply!

Posted by David Adelstein on June 30, 2016
Trial Perspectives / Comments Off on Just Say NO! to Frivolous Claims! Otherwise 57.105 May Apply!

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As a lawyer, it is important to examine your client or prospective client regarding the facts of their case. In this manner, it is important to conduct legal research to support legal arguments, especially arguments applied to the facts. The bottom line is that you want to make sure you are NOT filing a frivolous claim or defense, which is typically one that (a) is NOT supported by material facts necessary to support the claim or defense or (b) NOT supported by the application of the law. See Fla. Stat. s. 57.105. If you do, you could be exposed to sanctions—be liable for the opposing party’s attorney’s fees and costs. But such exposure can also run to the lawyer.

Florida Statute s. 57.105 provides:

(1) Upon the court’s initiative or motion of any party, the court shall award a reasonable attorney’s fee, including prejudgment interest, to be paid to the prevailing party in equal amounts by the losing party and the losing party’s attorney on any claim or defense at any time during a civil proceeding or action in which the court finds that the losing party or the losing party’s attorney knew or should have known that a claim or defense when initially presented to the court or at any time before trial:

(a) Was not supported by the material facts necessary to establish the claim or defense; or

(b) Would not be supported by the application of then-existing law to those material facts.

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(4) A motion by a party seeking sanctions under this section must be served but may not be filed with or presented to the court unless, within 21 days after service of the motion, the challenged paper, claim, defense, contention, allegation, or denial is not withdrawn or appropriately corrected.

There are attorneys that will serve what is known as a “57.105 motion for sanctions” telling you that unless you dismiss the claim or defense within 21 days (known as the safe harbor time period) they will file the motion and seek fees and costs associated with the claim for defense.  Some attorneys do this as an intimidation tactic.  Notwithstanding, an attorney should consider the substance and merits of the motion.

But, what if a party’s 57.105 motion is defective or they do not give the 21 days safe harbor time period? In a recent decision Watson v. Stewart Tilghman Fox & Bianchi, P.A., 41 Fla. L. Weekly D1523a (Fla. 4th DCA 2016), a party served a defective 57.105 motion for sanctions. Nonetheless, the trial court still awarded sanctions (fees and costs) against the plaintiff and her lawyer on the court’s own initiative based on the frivolousness of the plaintiff’s lawsuit.   The appellate court held that a trial court can award sanctions (fees and costs) on its own initiative (based on the frivolousness of the claim) and, if it does so, the 21 day safe harbor provision does not apply. OUCH!  

Please contact David Adelstein at dma@kirwinnorris.com or (954) 759-0026 or (407) 740-6600 if you have questions or would like more information regarding this article. You can also follow David Adelstein on Twitter @DavidAdelstein1.

 

 

 

 

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Challenging Standard for Granting Directed Verdict

Posted by David Adelstein on June 25, 2016
Evidence, Trial Perspectives / Comments Off on Challenging Standard for Granting Directed Verdict

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If there is a jury trial, there will be a motion for directed verdict. But, the standard for granting a motion for directed verdict is challenging; if the directed verdict is granted, an appeal will be filed arguing the trial court’s error in granting the directed verdict.

James v. City of Tampa, 2016 WL 3201221 (Fla. 2d DCA 2016) was a personal injury action. The issue at trial was whether the plaintiff’s injuries from a car accident constituted a permanent injury (as this issue impacted damages to be awarded to the injured plaintiff). At the conclusion of all of the evidence, the trial court granted the defendant’s motion for directed verdict on the issue of whether the plaintiff suffered a permanent injury, meaning the directed verdict prevented the jury from considering whether the injuries were permanent, and if so, damages associated with the permanent injuries. Naturally, the plaintiff appealed.

Regarding the challenging burden in granting a motion for directed verdict:

A motion for directed verdict should be granted only where no view of the evidence, or inferenced made therefrom, could support a verdict for the nonmoving party. In considering a motion for directed verdict, the court must evaluate the testimony in the light most favorable to the nonmoving party and every reasonable inference deduced from the evidence must be indulged in favor of the nonmoving party. In there are conflicts in the evidence or different or reasonable inferences that may be drawn from the evidence, the issue is factual and should be submitted to the jury. The standard of review on appeal of the trial court’s ruling on a defendant’s motion for directed verdict is the same test used by the trial court in ruling on the motion.

James, supra, quoting Sims v. Cristinzio, 898 So.2d 1004, 1005-06 (Fla. 2d DCA 2005).

Here, the appellate court had no choice but to reverse the directed verdict remanding the matter back to the trial court for a new trial as to damages. The plaintiff put on expert testimony regarding the issue of permanent damages and the defendant cross-examined the plaintiff and presented its own rebutting expert. Thus, the issue of permanency was really a question for the jury as the directed verdict would only be appropriate where “the evidence of injury and causation is such that no reasonable inference could support a jury verdict for the plaintiff…on the permanency issue.” James, supra.

 

Please contact David Adelstein at dma@kirwinnorris.com or (954) 759-0026 or (407) 740-6600 if you have questions or would like more information regarding this article. You can also follow David Adelstein on Twitter @DavidAdelstein1.

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Appeals Regarding Personal Jurisdiction

Posted by David Adelstein on June 18, 2016
Appeal / Comments Off on Appeals Regarding Personal Jurisdiction

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In a matter where a commercial landlord sued its tenant’s personal guarantors as the result of the tenant’s breach of the lease, the guarantors moved to dismiss the lawsuit based on personal jurisdiction. Check here for more on this matter.

A trial court’s ruling on personal jurisdiction is an immediately appealable ruling–a trial court’s determination relating to personal jurisdiction is an immediately appealable non-final order (non-final order meaning the order does not finally dispose of the lawsuit). See Fla.R.App.P. 9.130(a)(3)(C)(i).

A determination on personal jurisdiction is an important issue. If a court grants a motion to dismiss based on lack of personal jurisdiction, this means you cannot sue that entity in that state, e.g., Florida. And, if a court denies a motion to dismiss based on lack of personal jurisdiction, this means the moving party is subject to a lawsuit in that state, e.g., Florida. For this reason, the determination is appealable. The moving party will want to appeal if the court denies its motion to dismiss for lack of personal jurisdiction and it is now subject to being sued in Florida. Conversely, the plaintiff (suing party) will want to appeal if the court grants the motion to dismiss for lack of personal jurisdiction and the plaintiff can no longer sue that party in Florida.

Please contact David Adelstein at dma@kirwinnorris.com or (954) 759-0026 or (407) 740-6600 if you have questions or would like more information regarding this article. You can also follow David Adelstein on Twitter @DavidAdelstein1.

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