Evidence

A Promissory Note is NOT Hearsay

Posted by David Adelstein on April 23, 2016
Evidence / Comments Off on A Promissory Note is NOT Hearsay

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A promissory note is NOT regarded as hearsay. This means a party introducing a promissory note does not need to lay down the foundation to a hearsay exception such as the business records exception in order to admit the note into evidence.

The Fifth District Court of Appeal in Deutsche Bank National Trust Co., Etc. v. Alaqua Property, Etc., 41 Fla.L.WeeklyD994b (Fla. 5th DCA 2016) explained that a promissory note in a foreclosure action is NOT hearsay because it is NOT being offered to prove the truth of the matter asserted; rather, the note has independent legal significance, that being “to establish the existence of the contractual relationship and the rights and obligations of the parties to the note.” Deutsche Bank National Trust Co., supra.

Please contact David Adelstein at dadelstein@gmail.com or (954) 361-4720 if you have questions or would like more information regarding this article. You can follow David Adelstein on Twitter @DavidAdelstein1.

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Difference Between Lay Opinion Testimony and Expert Opinion Testimony

Posted by David Adelstein on April 07, 2016
Appeal, Evidence, Standard of Review / Comments Off on Difference Between Lay Opinion Testimony and Expert Opinion Testimony

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Although I have numerous blog articles regarding the appellate standard of review when it comes to the admissibility of evidence, it is important to remember that “[a] trial court’s ruling on the admissibility of evidence is reviewed for an abuse of discretion; however, the trial court’s interpretation of the evidence code is reviewed de novo.” L.L. v. The State of Florida, 41 Fla.L.Weekly D854a (Fla. 3d DCA 2016).

In L.L., a criminal case, a police officer testified that he smelled the strong odor of marijuana from the defendant and that a plastic bag in defendant’s possession contained marijuana. The defendant objected that the officer’s opinions about the smell being marijuana and the substance in the bag being marijuana was an improper lay opinion and constituted expert opinion testimony (governed by the Daubert standard). The trial court allowed this testimony and the issue on appeal was whether such testimony was expert opinion testimony or proper lay opinion (fact witness) testimony.

The appellate court held that the officer’s testimony or opinions about the smell and substance being marijuana was proper lay witness opinion testimony governed under Florida Evidence Code 90.701:

If a witness is not testifying as an expert, the [lay] witness’s testimony about what he or she perceived may be in the form of inference and opinion when:

(1) The witness cannot readily, and with equal accuracy and adequacy, communicate what he or she has perceived to the trier of fact without testifying in terms of inferences or opinions and the witness’s use of inferences or opinions will not mislead the trier of fact to the prejudice of the objecting party; and

(2) The opinions and inferences do not require a special knowledge, skill, experience, or training.

The appellate court’s holding included a very good discussion explaining in detail why the officer’s opinion was proper lay opinion testimony as opposed to expert opinion testimony governed by the Daubert standard:

In addition to the requirement that lay opinion testimony be based on the personal knowledge and perception of the witness, the Advisory Committee Notes explain that courts should consider the witness’s method of reasoning: “the distinction between lay and expert witness testimony is that lay testimony ‘results from a process of reasoning familiar in everyday life,’ while expert testimony ‘results from a process of reasoning which can be mastered only by specialists in the field.‘ ” …As one scholar has explained:

[T]he distinction lies in whether the witness’s reasoning process entails a reliable methodology beyond everyday reasoning. A lay witness, however experienced, offers no methodology beyond ordinary reasoning. An expert is equipped to draw more sophisticated, yet still reliable, inferences. The crux of expert testimony is that it presents inferences that are supported through the application of a reliable methodology. Thus, the witness who relies on experience to support an expert opinion cannot simply claim insights arrived at by applying everyday reasoning to that experience base, but must explain the methodology employed to reach that opinion. An experienced witness who does not bring such methodology to bear should be subject to the restrictions of the lay opinion rule.

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One important reason the Daubert standard [governing the admissibility of expert witness opinions] imposes a more demanding reliability inquiry upon expert opinion testimony is that the opinion results from a methodology or reasoning process that might be foreign to the trier of fact….But in cases such as the one now before us, even if the trier of fact does not have the personal experience necessary to identify the substance in question, the reasoning process is not “foreign in kind.” Many people who have seen and smelled marijuana would be able to recognize it in the same way they recognize anything else they have seen or smelled before.

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Here, Officer Munecas’s reasoning process is nothing that requires a specialist in the field of drug identification; it is reasoning familiar in everyday life.

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Finally, we hasten to add that although the more demanding Daubert admissibility standard does not apply to lay opinion testimony, there is nevertheless a reliability inquiry. Not only must lay opinion testimony be based on the witness’s personal knowledge, section 90.604, Florida Statutes, and perceptions, section 90.701, Florida Statutes, but the witness must have sufficient personal knowledge to support the opinion.

L.L., supra (internal citations omitted).

Please contact David Adelstein at dadelstein@gmail.com or (954) 361-4720 if you have questions or would like more information regarding this article. You can follow David Adelstein on Twitter @DavidAdelstein1.

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Discoverability of Opposing Party’s Attorney’s Fees Records

Posted by David Adelstein on March 24, 2016
Evidence, Trial Perspectives / Comments Off on Discoverability of Opposing Party’s Attorney’s Fees Records

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Interesting new Florida Supreme Court case regarding the discoverability of an opposing party’s attorney’s fees records in a dispute regarding the reasonableness of your fees.

For instance, say you are entitled to your reasonable attorney’s fees after prevailing in a dispute. The parties are entitled to an evidentiary fee hearing to determine the reasonableness of your fees—to determine the reasonable hourly rate and number of expended hours. Oftentimes, the party that prevailed serves discovery on the opposing / contesting party to discover their attorney’s fees records. The opposing / contesting party typically objects to this discovery as being irrelevant. But, not so fast…

The Florida Supreme Court in Patton v. Geico Ins. Co., 41 Fla.L.Weekly S115a (Fla. 2016) recently chimed in on this specific issue in a matter where a party recovered a judgment against an insurance carrier. The Florida Supreme Court expressed:

[T]he billing records of opposing counsel are relevant to the issue of reasonableness of time expended in a claim for attorney’s fees, and their discovery falls within the discretion of the trial court when the fees are contested….The hours expended by the attorneys for the [defendant] insurance company will demonstrate the complexity of the case along with the time expended, and may belie a claim that the number of hours spent by the plaintiff was unreasonable, or that the plaintiff is not entitled to a full lodestar computation, including a multiplying factor.

It is safe to say that this rationale is probably not limited to an entitlement of attorney’s fees against an insurance company. Rather, the rationale could reasonably apply to any dispute where the attorney’s fees are contested. What if the opposing / contesting party had a higher hourly rate? What if the opposing / contesting party billed more hours?  The answers to these questions are the reasons why the opposing / contesting party’s attorney’s fees records are sought when your fees are contested.

 

Please contact David Adelstein at dadelstein@gmail.com or (954) 361-4720 if you have questions or would like more information regarding this article. You can follow David Adelstein on Twitter @DavidAdelstein1.

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Make Sure to Timely Raise Your Daubert Objection to Expert Testimony

Posted by David Adelstein on March 09, 2016
Evidence, Expert Testimony / Comments Off on Make Sure to Timely Raise Your Daubert Objection to Expert Testimony

 

If you are going to raise a Daubert objection or challenge (or request a Daubert hearing), you need to TIMELY do so before the expert witness testifies. A Daubert motion / challenge / hearing relates to the admissibility of an expert witness’ testimony. As you can imagine, this is an extremely important issue as many cases depend on expert witness testimony to support their burden of proof.

In Rojas v. Rodriguez, 41 Fla.L.Weekly D423a (Fla. 3d DCA 2016), a defendant raised a Daubert objection post-verdict. The defendant was challenging the admissibility of the testimony of plaintiff’s neurosurgeon expert in requesting a new trial. The trial court granted the defendant’s motion. On appeal, the appellate court reversed ordering the reinstitution of the jury’s verdict because the defendant did NOT timely raise its Daubert objection:

Moreover, it was incumbent upon the defendant, as the challenging party, to timely raise a Daubert objection and request a hearing before the trial court. Given the trial court’s role as “gatekeeper” in the Daubert context, it stands to reason that such an objection must be timely raised to allow the trial court to properly perform its role:…

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Here, there was no timely Daubert objection, nor is there any indication that exceptional circumstances existed to merit consideration of the defendant’s untimely objection. As such, the trial court erred in granting the defendant’s motion. Accordingly, we reverse the order on appeal and remand so that the trial court may reinstitute the jury’s verdict. Because the defendant failed to make a timely Daubert objection, we do not reach the issue of whether the neurosurgeon’s testimony would have been admissible under Daubert.

Please contact David Adelstein at dadelstein@gmail.com or (954) 361-4720 if you have questions or would like more information regarding this article. You can follow David Adelstein on Twitter @DavidAdelstein1.

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Agent’s Out-of-Court Statements Could Constitute Admissions by a Party Opponent

Posted by David Adelstein on March 05, 2016
Evidence / Comments Off on Agent’s Out-of-Court Statements Could Constitute Admissions by a Party Opponent

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Below is an example in a criminal trial of the exception to the hearsay rule referred to as admissions against party opponents when a party’s agent makes an out-of-court statement. Check out this article and this article for more on this important hearsay exception embodied in Florida Statute s. 90.803(18).

In Osorio v. State of Florida, 41 Fla.L.WeeklyD547b (Fla. 4th DCA 2016), the police used a confidential informant to make an arrest in a drug case. The confidential informant happened to be a co-worker of the defendant (that had previously been arrested on an unrelated drug charge and turned into an informant to obtain credit in his prosecution). The defendant was relying on an entrapment defense. During the defendant’s cross-examination of a detective at trial, the court refused to allow the detective to testify about an issue that the co-worker / informant relayed to the detective. Then, when the defendant took to stand to testify, the trial court refused to allow the defendant to testify about statements his co-worker / informant made. The court precluded this testimony based on the hearsay rule since both the detective and defendant would be testifying about out-of-court statements from the co-worker / informant offered for the truth of the matter asserted.

Could the co-worker / informant, acting as an agent of the police, be classified as a party-opponent to fall within the hearsay exception known as admissions against party opponents.   The court said yes!

“[A]n agent is one who consents to act on behalf of some person, with that person’s acknowledgment, and is subject to that person’s control.” Osorio, supra, citing Goldschmidt v. Holman, 571 So.2d 422, 424, n.5 (Fla. 1990).

The court held that the co-worker / informant was serving as an agent since the police encouraged his involvement including setting up the drug-buy that led to the defendant’s arrest in furtherance of obtaining credit in his prosecution.  As an agent, the co-worker / informant’s out-of-court statements did fall within the hearsay exception known as admissions against a party opponent. The statements made by the co-worker / informant were statements by the party’s [the state / police] agent concerning a matter within the scope of his agency and made during the existence of the relationship.   See Fla. Stat. s. 90.803(18).  The court held it was error not to allow the defendant to introduce these out-of-court statements that restricted the defendant’s ability to put on his entrapment defense.

 

Please contact David Adelstein at dadelstein@gmail.com or (954) 361-4720 if you have questions or would like more information regarding this article. You can follow David Adelstein on Twitter @DavidAdelstein1.

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Witness Laying Foundation for Business Records Exception Need Not be the Person that Prepared the Business Records

Posted by David Adelstein on February 16, 2016
Appeal, Evidence / Comments Off on Witness Laying Foundation for Business Records Exception Need Not be the Person that Prepared the Business Records

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If you have visited this blog before, then you know the importance I place on the business records exception to the hearsay rule in civil business disputes. (Check out this article too.) Lately, the business records exception to the hearsay rule is a hot topic in mortgage foreclosure cases.

In yet another foreclosure case, Wells Fargo Bank, N.A., as Trustee, on Behalf of the Harborview Mortgage Loan Trust Mortgage Loan Pass-Through Certificates, Series 2007-1 v. Balkisson, 41 Fla.L.Weekly D308a (Fla. 4th DCA 2016), the trial court entered an involuntary dismissal in favor of the borrower and against the lender after sustaining the borrower’s objection to hearsay based on the lender not properly laying the foundation for the business records exception to the hearsay rule. (An involuntary dismissal is essentially the same thing as a directed verdict in a non-jury bench trial. Similar to a directed verdict, the standard of appellate review for a motion for involuntary dismissal is de novo. See Wells Fargo Bank, supra.) The trial court sustained the hearsay objection because the loan servicer’s records custodian witness was unable to describe the specialized computer programs utilized to generate the payment history and default notice. The trial court’s ruling in sustaining the objection precluded the lender from presenting the payment history and the default notice into evidence meaning the lender could not prove its case at trial. The Fourth District Court of Appeal reversed.

The Fourth District explained that a testifying witness establishing the business records exception to the hearsay rule “need not be the person who actually prepared the business records. Instead, the witness just need be well enough acquainted with the [record keeping] activity to provide testimony.” Wells Fargo Bank, supra (internal quotations and citation omitted).

While the witness was not familiar with how data was entered into the computer system, there is no requirement that the witness have such knowledge to satisfy the business records exception to the hearsay rule. The witness was sufficiently familiar with the loan servicer’s practices and procedures in generating the payment history and notice of default to lay the foundation for the business records exception.

 

Please contact David Adelstein at dadelstein@gmail.com or (954) 361-4720 if you have questions or would like more information regarding this article. You can follow David Adelstein on Twitter @DavidAdelstein1.

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Excited Utterance Hearsay Exception

Posted by David Adelstein on January 23, 2016
Evidence / Comments Off on Excited Utterance Hearsay Exception

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I have discussed that hearsay is inadmissible evidence. Again, hearsay “is a statement, other than one made by the declarant while testifying at the trial or hearing, offered in evidence to prove the truth of the matter asserted.” Fla.Stat. 90.801(1)(c).

While hearsay is inadmissible, there are exceptions that allow hearsay to be admissible at trial.

One hearsay exception is known as an “excited utterance.” Typically, this hearsay exception is more applicable in criminal trials than civil trials. An excited utterance is a “statement or excited utterance relating to a startling event or condition made while the declarant was under the stress of excitement caused by the event or condition.” Fla.Stat. 90.803(2). An excited utterance is admissible even though the declarant of the statement does not testify to making the statement at trial.

“There are three requirements for a statement to qualify as an excited utterance: (1) there must have been an event startling enough to cause nervous excitement; (2) the statement must have been made before there was time to contrive or misrepresent; and (3) the statement must have been made while the person was under the stress of excitement caused by the startling event.”

Smith v. Florida, 2016 WL 64341, *4 (4th DCA 2016) (internal quotation omitted).

For example, Smith was a murder trial. At trial, the murder victim’s daughter testified she called 911 and told the 911 operator that her aunt, the criminal defendant’s sister, told her that he seriously hurt the victim. The aunt then called 911 telling the operator that she saw blood and pleading with the operator to send help. In response to the 911 calls, the police discovered the victim stabbed to death.

At trial, the aunt denied making the statement to the victim’s daughter that the defendant told her that he seriously hurt the victim. The aunt, of course, was not the most credible since the defendant was her brother. The issue was whether the daughter could testify what the aunt told her (that the defendant told the aunt that he seriously hurt the vicim) since the statement constitutes hearsay.

The appellate court affirmed that the daughter could testify what the aunt told her since the aunt’s statement was an excited utterance: a) the startling event that caused the aunt’s nervous excitement was the thought that the victim was seriously hurt or dead; b) the aunt made the statement to the victim’s daughter immediately after she heard from her brother; and c) the statement was made before the aunt even called 911 so it was clearly made while the aunt was under the stress of the event and before there was time to make any misrepresentation. Further, the startling event the aunt experienced was supported by the aunt’s independent 911 call.

Please contact David Adelstein at dadelstein@gmail.com or (954) 361-4720 if you have questions or would like more information regarding this article. You can follow David Adelstein on Twitter @DavidAdelstein1.

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Hearsay can Only be Admitted for Another Purpose if Such Purpose is a Material Issue

Posted by David Adelstein on January 10, 2016
Evidence / Comments Off on Hearsay can Only be Admitted for Another Purpose if Such Purpose is a Material Issue

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Sometimes, a party will try to introduce hearsay by arguing that that the document/testimony is not being offered to prove the truth of the matter asserted (hearsay), but instead, is being offered for another purpose. This is an avenue to admit evidence that would otherwise be excluded under the hearsay exclusion.  This was the situation in the employment litigation case, Mootry v. Bethune-Cookman University, Inc., 41 Fla. L. Weekly D146a (Fla. 5th DCA 2015).

In this case, the University terminated a tenured professor for cause and the professor sued. At trial, the University offered into evidence a report prepared by an investigator that summarized an investigation into findings of sexual harassment committed by the professor by victims not named in the report. The professor argued that the report contains numerous hearsay statements, particularly, the sexual harassment allegations by the unnamed victims. The University, however, stated that the report was not being offered for the truth of the matter asserted, but was offered to establish the reasonableness of the University’s actions in terminating the professor’s employment.

The appellate court held that it was harmful error for the trial court to admit the report with the hearsay statements into evidence. The court held, “when an out-of-court statement is being ‘offered for a purpose other than proving the truth of its contents[, it] is admissible only when the purpose for which the statement is being offered is a material issue in the case.” Mootry, supra, quoting King v. State, 684 So.2d 1388, 1389-90 (Fla. 1st DCA 1996).

The appellate court found that the reasonableness of the University’s actions was not a material issue in the dispute because the professor could only be properly terminated for cause if he breached his faculty agreement. The reasonableness of the University’s decision to terminate the professor had no bearing on whether the professor actually breached his faculty agreement. For this reason, the court held that the report was hearsay because it was actually being offered to prove the truth of the matter asserted that the professor sexually harassed students.

Please contact David Adelstein at dadelstein@gmail.com or (954) 361-4720 if you have questions or would like more information regarding this article. You can follow David Adelstein on Twitter @DavidAdelstein1.

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Summary Judgment Must be Based on Admissible Evidence

Posted by David Adelstein on December 31, 2015
Evidence / Comments Off on Summary Judgment Must be Based on Admissible Evidence

 

A party moving for summary judgment must rely on admissible evidence in the record. Arlen Realty, Inc. v. Penn Mut. Life Ins. Co., 386 So.2d 886 (Fla. 1st DCA 1980).

Parties oftentimes submit an affidavit in support of a motion for summary judgment in order to get certain testimony or documentary evidence into the record. When a party submits an affidavit to get a document into the record, the party still needs to authenticate the document and lay its foundation in the affidavit. See Alavi v. Garcia, 140 So.3d 1141 (Fla. 5th DCA 2014) (party required to lay foundation for promissory note in summary judgment affidavit); Bryson v. Branch Banking and Trust Co., 75 So.3d 783 (Fla. 2d DCA 2011) (unauthenticated default letters were insufficient for summary judgment consideration); Southern Developers & Earthmoving, Inc. v. Caterpillar Financial Services Corp., 56 So.3d 56 (Fla. 2d DCA 2011) (trial court properly disallowed letter on summary judgment that was not authenticated); Mitchell Bros., Inc. v. Westfield Ins. Co., 24 So.3d 1269 (Fla. 1st DCA 2009) (affidavit with schedule of payments to support damages was insufficient for consideration on summary judgment as the schedule of payments was hearsay and the business records exception to the hearsay rule was not established); Dutilly v. Department of Health & Rehabilitative Services, 450 So.2d 1195 (Fla. 5th DCA 1984) (party relying on blood tests should have submitted affidavit (i) of record custodian of blood tests to support business records exception to the hearsay rule or (ii) of the technician that performed the blood tests).

 

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How the Defense of Set-Off Applies

Posted by David Adelstein on December 25, 2015
Evidence / Comments Off on How the Defense of Set-Off Applies

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Set-off is a popular topic or defense raised in civil disputes.

In contract actions, set-off must be raised as an affirmative defense and proven at trial (and determined by the trier of fact) or else the defendant waives the right to assert set-off. See Felgenhauer v. Bonds, 891 So.2d 1043, 1045 (Fla. 2d DCA 2004).

What about tort actions such as negligence actions in disputes involving personal injury or property damage? For instance, say a plaintiff sues three defendants in negligence for the same damage. Prior to trial, the plaintiff settled with two of the defendants for a total of $100,000 and gave the defendants releases. The remaining defendant proceeds to trial but a) thinks its liability is no more than $100,000 and b) wants to reap the benefit of the $100,000 already obtained by the plaintiff from the other two defendants. In tort actions, set-off is not an affirmative defense to be determined by the trier of fact “but is a determination regarding damages to be made by the court after the [jury] verdict is rendered [in a jury trial].” Felgenhauer, 891 So.2d at 1045.

On this point, Florida Statutes s. 46.015 and 768.041 similarly state:

 

s. 46.015

(1) A written covenant not to sue or release of a person who is or may be jointly and severally liable with other persons for a claim shall not release or discharge the liability of any other person who may be liable for the balance of such claim.

(2) At trial, if any person shows the court that the plaintiff, or his or her legal representative, has delivered a written release or covenant not to sue to any person in partial satisfaction of the damages sued for, the court shall set off this amount from the amount of any judgment to which the plaintiff would be otherwise entitled at the time of rendering judgment.

(3) The fact that a written release or covenant not to sue exists or the fact that any person has been dismissed because of such release or covenant not to sue shall not be made known to the jury.

 

s. 768.041

(1) A release or covenant not to sue as to one tortfeasor for property damage to, personal injury of, or the wrongful death of any person shall not operate to release or discharge the liability of any other tortfeasor who may be liable for the same tort or death.

(2) At trial, if any defendant shows the court that the plaintiff, or any person lawfully on her or his behalf, has delivered a release or covenant not to sue to any person, firm, or corporation in partial satisfaction of the damages sued for, the court shall set off this amount from the amount of any judgment to which the plaintiff would be otherwise entitled at the time of rendering judgment and enter judgment accordingly.

(3) The fact of such a release or covenant not to sue, or that any defendant has been dismissed by order of the court shall not be made known to the jury.

 

Typically, these set-off statutes apply when the plaintiff received money from a defendant / tortfeasor who was vicariously liable for the other defendant’s acts. Felgenhauer, 891 So.2d at 1045-46.   (The vicariously liable party is responsible to the plaintiff to the same extent as the primary [defendant] actor; both are jointly liable for all of the harm that the primary actor has caused. See Grobman v. Posey, 863 So.2d 1230 (Fla. 4th DCA 2003)). Stated differently, “[s]ettlement proceeds must be set off against the jury verdict where defendants [the settling defendant and non-settling defendant] are liable for the same injury.” Yellow Cab Co. of St. Petersburg, Inc. v. Betsey, 696 So.2d 769, 772 (Fla. 2d DCA 1996).

The objective is to prevent the plaintiff from obtaining a windfall by obtaining overlapping compensation for the same damages. Cornerstone SMR, Inc. v. Bank of America, N.A., 163 So.3d 565, 569 (Fla. 4th DCA 2015). But, where there are separate and distinct claims involving different elements of damages, set-off is inappropriate. Gordon v. Marvin M. Rosenberg, D.D.S., P.A., 654 So.2d 643, 645 (Fla. 4th DCA 1995). For this reason, when settling with one defendant in a dispute under different theories of liability /claims involving different elements of damages, it is important to allocate the settlement amount in the release agreement between the claims. “Where a settlement is undifferentiated and general [and not allocated amongst the claims], the aggregate of the amount of the settlement should be set off against the judgment [to prevent the appearance of double recovery for the same damages].” Cornerstone SMR, 163 So.2d at 569.

Let’s break this down as applied to the above hypothetical. First, releasing the two defendants prior to trial does not operate as a release of the remaining defendant. Second, the court shall set-off any amount the plaintiff received from the other two defendants in the judgment the plaintiff receives since it involves the same damage, meaning the set-off would reduce the jury verdict and would be embodied in the final judgment. And, third, the fact that the other two defendants were released and then dismissed from the action in consideration of $100,000 prior to trial shall not be disclosed to the jury because this does not need to be proven at trial by the remaining defendant or impact any rulings at trial.  

On the other hand, if there was an argument that there were separate theories of liability / claims against the other two defendants and potentially different elements of damages, the plaintiff would want to allocate the settlement consideration in the release agreement to these separate theories of liability / claims to create the argument that set-off is not appropriate. (See also this article for an example regarding the application of set-off in a multiparty construction dispute.) 

 

Please contact David Adelstein at dadelstein@gmail.com or (954) 361-4720 if you have questions or would like more information regarding this article. You can follow David Adelstein on Twitter @DavidAdelstein1.

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