Trial Perspectives

Injunctive Relief + Attorney’s Fees Awarded in Favor of an Owner and Against Her Association

Posted by David Adelstein on May 12, 2018
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Here is a case that may give associations some degree of consternation.  I think it should because it supports permanent injunctive relief against an association to comply with its governing documents when managing or maintaining a surface water management system / stormwater management system.   This case, discussed below, would extend beyond a surface water management system to any covenant in the governing documents.  

In Coconut Creek Homeowner’s Association, Inc. v. Gonzalez,  43 Fla.L.Weekly D1045a (Fla. 4th DCA 2018), a homeowner sued her homeowner’s association for failing to manage the association’s surface water management system.  The homeowner sued the association for breach of the governing documents (Declaration, bylaws, etc.) and for a permanent / mandatory injunction to compel the association to comply with its governing documents to fix the swales and drainage system (common elements owned by the association).   The lack of management of the surface water management system caused flooding problems and damage to the homeowner’s home.

The jury found that the association breached its governing documents in failing to manage the surface water management system, but awarded the homeowner $0 caused by the breach associated with her claimed damages.  But, the trial court, as affirmed by the appellate court, granted a mandatory / permanent injunction against the association to enforce restrictive covenants in the governing documents. Specifically, the injunctive relief was issued to order the association to fix the swales and drainage system and comply with its governing documents.  

Now, the association perhaps thought this was not all that bad because it did not owe the homeowner any monetary damages based on the jury’s verdict of $0.  However, the appellate court found that because the homeowner prevailed on the significant issues of her case, she is entitled to her attorney’s fees and costs.  Thus, a mandatory / permanent injunction is issued against the association requiring it to comply with the governing documents and it is liable for the homeowner’s attorney’s fees and costs, which are likely significant after a trial.  Please check out this article for more information relating to the attorney’s fees aspect of this case. 

If you live in a community governed by an association (whether a homeowner’s association or condominium association), make sure you seek counsel that appreciates the issues associated with your governing documents.  And, an association needs to likewise consider the issues so it understands its responsibilities under the governing documents and potential outcomes associated with owner disputes.

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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Mid-litigation Monetary Settlement with Co-Defendant

Posted by David Adelstein on May 05, 2018
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I recently discussed a doctrine that applies in negligence cases known as the undertaker’s doctrine.  Some may also call this the no good deed goes unpunished doctrine.  Just kidding; but, this undertaker’s doctrine maintains that if you undertake a service, i.e., a good deed, you must do so with reasonable care as you assumed a duty to prevent the beneficiary of that service from harm.  

For instance, a tenant sued the owner of the condominium he (and his family) was renting and his real estate agent for water intrusion and mold problems in the unit.  The tenant claimed the real estate agent was negligent because the agent agreed to fix the problems with the unit but neglected to do so.  This is where the undertaker’s doctrine comes into play–the agreement to undertake a service exposed the real estate agent to a duty to use reasonable care with that service.  

The owner of the unit settled with the tenant for $82,000 resulting in a final judgment against the owner.  The real estate agent argued that the negligence claim against him should be deemed moot in light of this settlement since the agent was being sued for the same damages.  The appellate court disagreed because there was nothing in the record to reflect that the settlement amount with the owner included ALL of the tenant’s damages.

Mid-litigation monetary settlements are often less than the total amount of damages that the plaintiff was claiming. Each side gives up something when they settle, including some of the plaintiff’s potential monetary damages award.”  Muchnick v. Goihman, 43 Fla.L.Weekly D986b (Fla. 3d DCA 2018).   The settlement amount would serve as a set-off from any judgment amount or verdict awarded against the agent to avoid any windfall to the tenant; however, the agent does not get to put the cart before the horse and argue the case against him is moot because the plaintiff settled with the co-defendant. 

 

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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Florida’s Uniform Trade Secrets Act cannot be used to Restrict Competition

Posted by David Adelstein on April 30, 2018
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Florida’s Uniform Trade Secrets Act is contained in Florida Statutes Chapter 688.  This Act authorizes  courts to take reasonable steps to preserve the confidentiality of trade secrets including ordering injunctive relief to prevent a party (such as a former employee) from misappropriating trade secrets.  Norton v. American LED Technology, Inc., 43 Fla.L.Weekly D951a (Fla. 1st DCA 2018).   However, as confirmed by the First District in Norton, Florida’s Uniform Trade Secrets Act cannot be used as a sword to restrict or stifle direct competition.  In other words, it is improper for a trial court to issue a temporary injunction restricting direct competition based on Florida’s Uniform Trade Secrets Act.  Norton, supra.

Please make sure to consult with counsel if you have an issue dealing with trade secrets or the preservation of the same.  This includes your rights when you believe a party is misappropriating your trade secrets. 

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 Entered in Favor of Defendant on Equitable Subrogation Claim

Posted by David Adelstein on April 22, 2018
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I recently wrote an article how there are times when a party is seeking reimbursement for solely economic losses, their best recourse is an equitable subrogation claim.   The article also discusses the application of equitable subrogation dealing with an actual fact pattern.

Equitable subrogation, you say?  In an equitable subrogation claim, a party pays for damages (or a debt) it believes were caused by another party.  The party then pursues reimbursement against the party it believes primarily responsible for the damages or debt.  No one wants to pay for damages or a debt it believes were caused by a third party!

There are five (5) elements to an equitable subrogation claim that the subrogee, the party that paid off the damages or debt, must prove:

  1. The party (subrogee) made the payment to protects its own interests;
  2. The party (subrogee) did not volunteer the payment — it was not making the payment as a volunteer;
  3. The party (subrogee) was not primarily liable for the damages or debt it seeks reimbursement for; 
  4. The party (subrogee) paid off the entire debt it seeks reimbursement for; and
  5. Subrogation would not work any injustice, i.e., it would not be unfair.

Tank Tech, Inc. v. Valley Tank Testing, L.L.C., 43 Fla.L.Weekly D868a (Fla. 2d DCA 2018) quoting Dade Cty. Sch. Bd. v. Radio Station WQBA, 731 So.2d 638, 646 (Fla. 1999).

Notably, in Tank Tech, Inc., the trial court granted summary judgment against the party pursing equitable subrogation. Summary judgment was granted in favor of the defendant.  The appellate court reversed for the factual reasons discussed in the article.  

As you may know from reading this blog, a motion for summary judgment is reviewed on appeal under a de novo standard of appellate review.  Summary judgment is only proper if there are no genuine issues of material fact and the party moving for summary judgment is entitled to a judgment as a matter of law.

Where the defendant is the party moving for summary judgment, as here, ‘neither the trial court nor this court determines whether the plaintiff can prove [its] case; our function solely is to determine whether the pleadings, depositions, and affidavits conclusively show that the plaintiff cannot prove [its] case.’”  Tank Tech, Inc., supra, quoting Crandall v. S.W. Fla. Blood Bank, Inc., 581 So.2d 593, 595 (Fla. 2d DCA 1991).  The takeaway is that a plaintiff is NOT required to prove its entire case when responding to a defendant’s motion for summary judgment and the court’s job is not to determine whether the plaintiff can prove its case at trial.  Rather, the job is to determine whether the the undisputed material facts “conclusively show that the plaintiff cannot prove its case.”  Id.

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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Attorney’s Fee Arrangements can be Creative or Innovative

Posted by David Adelstein on April 13, 2018
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Lawyers get it.  Generally, people do not like to spend money on lawyers.  There are certainly exceptions where clients value the relationship with a lawyer knowing that the services provided and advice given is worth the fees.  Ideally, this should be the sentiment from anyone that feels they need a lawyer, even if the advice paid for is to steer you in a more focused direction based on the pros/cons of the claims and issues you are dealing with.  But, money is important and decisions cannot be made in a vacuum without understanding associated costs.  

I get that not everyone wants to have to deal with the potential unknown of hourly lawyer billing, the traditional legal model.  There are creative or innovative models out there outside of hourly lawyer billing that can be explored in certain matters, but the dynamic of that model has to work for both the client and lawyer.  If you are interested in learning a little more about the nuts and bolts of creative or innovative attorney’s fee models where there is a focus on results, performance, or meeting budgetary or target parameters, check out the ebook above. Look, there is no one-size-fits-all model.  The key takeaway is that creativity can be implemented in a business model so the attorney-client relationship works for both the attorney and the client!

 

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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Forum Selection / Venue Provisions in Contracts are Enforceable

Posted by David Adelstein on March 31, 2018
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If you have a dispute, one of the first considerations should be “where do I sue?” If the dispute may arise out of or relate to a contract, you want to look at your contract.  Many contracts contain forum selection or venue provisions identifying the exclusive venue governing your dispute. 

For instance, the provision may say something to the effect, “The exclusive venue for any dispute arising out of or relating to this contract shall be in Miami-Dade County Florida.”   This means that if you plan to sue you need to do so in a court located in Miami-Dade County, Florida, even if you have an argument that the venue should be in a different, more preferred location.  Venue and forum selection provisions are important provisions because they contemplate where a lawsuit must be brought in the event such a lawsuit occurs down the road.  While of course you hope for the best with any agreement, you know that disputes occur, so you plan for the potentiality of that risk.

As a contracting party, you have the right to contractually agree to a forum selection / venue provision; you can contractually agree to the forum governing your dispute.  Baker v. Economic Research Services, Inc. 43 Fla.L.Weekly D643a (Fla. 1st DCA 2017).  Absent limited exceptions, these provisions will be deemed enforceable.  Id.   A judicial order as to venue is also the type of non-final order that can be appealed immediatelyId.  Thus, even if you sued in a venue contrary to the forum selection provision in your contract and the trial court agreed with you, the other side can appeal this order immediately arguing that the forum selection provision places venue in a different location.

In Baker, employees entered an employment agreement that contained a forum selection provision that placed venue in Delaware.  The employees left to work for a competitor and the employer sued its former employees in Leon County, Florida.  An argument the employees raised was that the lawsuit should have been filed in Delaware, not Florida, based on the forum selection provision.  The trial court denied the motion.  But, remember, an order as to venue can be appealed immediately so the employees appealed.  The appellate court reversed the trial court finding that claims arising out of or relating to the agreements need to be filed in Delaware based on the forum selection provision.  The forum selection provision survives any termination of the agreements such that if the employer’s claims have a significant relationship (nexus) to the agreement, then the claims must be brought in Delaware.

As you can see, forum selection provisions are important because they will largely dictate where a party must sue or be sued.  Take such provisions into consideration when entering an agreement.

For more information on forum selection / venue provisions, you can also check out this article.

 

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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Set-Off when Entering into Settlements in Multi-Party Disputes

Posted by David Adelstein on March 25, 2018
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Lawsuits oftentimes involve multiple parties.  This could include multiple defendants or third-party defendants, whatever the case may be.  During the course of the dispute, there are avenues for settlement.  With a multi-party dispute, sometimes the stars are aligned where a favorable global settlement works out.  Sometimes, a party needs to settle with some, but not all, of the defendants.  This means the plaintiff will need to try the case against the remaining defendants (or parties).  The remaining defendants, obviously, want the settlements with the settling defendants to be used to set-off any damages or judgment entered against them.  For example, if the plaintiff settles with multiple defendants for $1 Million and recovers damages against the remaining defendants for $1.5 Million at trial, the remaining defendants want the $1 Million in pre-suit settlements to be set-off from their damages award.  This means their exposure is not a $1.5 Million judgment, but instead, a $500,000 principal judgment — a big difference, right!  

The issue of set-off is an issue that should not be overlooked in multi-party disputes, specifically from the plaintiff considering pre-suit settlements.  Time should be dedicated to trying to craft settlements to truly prevent a set-off, which is designed to prevent the plaintiff from recovering a gratuitous windfall.  For more information on a construction defect case where the issue of set-off hurt a plaintiff based on the broad wording in settlement agreements, view this article.  Due to pre-suit settlements, the plaintiff’s damages against the remaining defendants at trial were reduced by the total sum of the settlements.  All because of this set-off doctrine; had the settlement agreements been drafted differently, perhaps the plaintiff’s damages awarded at trial would not have been set-off by the pre-suit settlements.

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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The Not Widely Known Harris Act: Protection of Private Property Rights

Posted by David Adelstein on March 18, 2018
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There is a Florida statute not universally known called the “Bert J. Harris, Jr., Private Property Rights Protection Act” and oftentimes called the “Harris Act” for ease of reference.   The Harris Act is embodied in Florida Statute s. 70.001 (found here) and it deals with the protection of private property rights.  More specifically, it provides a private cause of action when the existing use (or vested rights) of property is inordinately burdened by the Florida government (including agencies thereof).  The Harris Act has some teeth in certain situations, as demonstrated below in a case example, and is a good Act to know because it does create a private cause of action.

The Harris Act was enacted by the Florida Legislature in 1995 as a mechanism to protect and compensate any landowner whose property is affected by government action not rising to the level of a taking. To prevail under the Harris Act, the property owner must prove that “a specific action of a governmental entity has inordinately burdened an existing use of real property or a vested right to a specific use of real property.” Accordingly, when a claim under the Harris Act is presented for judicial review, the court must first consider whether a claimed “existing use of the real property” or a claimed “vested right to a specific use of the real property” actually existed. If it finds either, it must next determine whether the government action inordinately burdened the property. If the court also finds that there was an inordinate burden, then it must impanel a jury to determine the total amount of compensation to the property owner for the loss caused by the inordinate burden to the property. The party seeking relief under the Harris Act bears the burden of proof. 

Ocean Concrete, Inc.  v. Indian River County, Board of County Commissioners, 43 Fla. L. Weekly D577a (Fla. 4th DCA 2018) (internal citations omitted).

The Harris Act starts off as follows:

(1) This act may be cited as the “Bert J. Harris, Jr., Private Property Rights Protection Act.” The Legislature recognizes that some laws, regulations, and ordinances of the state and political entities in the state, as applied, may inordinately burden, restrict, or limit private property rights without amounting to a taking under the State Constitution or the United States Constitution. The Legislature determines that there is an important state interest in protecting the interests of private property owners from such inordinate burdens. Therefore, it is the intent of the Legislature that, as a separate and distinct cause of action from the law of takings, the Legislature herein provides for relief, or payment of compensation, when a new law, rule, regulation, or ordinance of the state or a political entity in the state, as applied, unfairly affects real property.

(2) When a specific action of a governmental entity has inordinately burdened an existing use of real property or a vested right to a specific use of real property, the property owner of that real property is entitled to relief, which may include compensation for the actual loss to the fair market value of the real property caused by the action of government, as provided in this section.

The term “existing use” as used in the Harris Act means:

(3)(b) (1) An actual, present use or activity on the real property, including periods of inactivity which are normally associated with, or are incidental to, the nature or type of use; or

(3)(b)(2) Activity or such reasonably foreseeable, nonspeculative land uses which are suitable for the subject real property and compatible with adjacent land uses and which have created an existing fair market value in the property greater than the fair market value of the actual, present use or activity on the real property.

The term inordinately burdened” as used in the Harris Act means:

(3)(e)(1) Mean that an action of one or more governmental entities has directly restricted or limited the use of real property such that the property owner is permanently unable to attain the reasonable, investment-backed expectation for the existing use of the real property or a vested right to a specific use of the real property with respect to the real property as a whole, or that the property owner is left with existing or vested uses that are unreasonable such that the property owner bears permanently a disproportionate share of a burden imposed for the good of the public, which in fairness should be borne by the public at large.

(3)(e)(2) Do not include temporary impacts to real property; impacts to real property occasioned by governmental abatement, prohibition, prevention, or remediation of a public nuisance at common law or a noxious use of private property; or impacts to real property caused by an action of a governmental entity taken to grant relief to a property owner under this section. However, a temporary impact on development, as defined ins. 380.04, that is in effect for longer than 1 year may, depending upon the circumstances, constitute an “inordinate burden” as provided in this paragraph.

In determining whether reasonable, investment-backed expectations are inordinately burdened, consideration may be given to the factual circumstances leading to the time elapsed between enactment of the law or regulation and its first application to the subject property.

The recent, factually complicated case, Ocean Concrete, Inc., discusses the application of the Harris Act.   Here, a plaintiff purchased undeveloped property that was zoned light industrial.  The plaintiff wanted to build a concrete batch plant.  The light industrial zoning allowed for this use.  

During the site plan review and application process with the County, a neighboring city and other members of the community asked the County to deny the proposed concrete batch plant project.   They wanted the County to modify the industrial light zoning code to preclude using the property as a concrete batch plant or any plant that processes large quantities of materials and would generate loud noise and dust. The County’s Board of Commissioners voted to approve the modification to the zoning code without any exception as to vested rights.  After dealing with certain administrative nuances and appeals and the plaintiff ultimately losing the property through foreclosure, the plaintiff asserted a claim against the County under the Harris Act.   

The trial court held there was no violation of the Harris Act by the County so the plaintiff’s damages were not presented to a jury.  In a de novo appellate standard of review, the appellate court reversed and found that the County did violate the Act and remanded the case back to a trial on damages.

Applying the applicable law, nothing about the physical or regulatory aspects of the property at the time of the government regulation made Appellants’ [plaintiff] expectations for the development of a concrete batch plant unreasonable. A concrete batch plant was a permitted use under the zoning code as a matter of right and throughout the site-plan approval process, Mr. Maib [plaintiff] was led to believe that approval was inevitable. Further, Mr. Maib obtained the services of an expert engineer who told him that the development was feasible. Finally, the property abutted a railroad and Mr. Maib was able to install a spur to facilitate the importation and exportation of materials. That the overall undertaking may have been expensive and a significant task does not invalidate the fact that, based on the property itself, Appellants’ investment-backed expectations were reasonable.

Ocean Concrete, Inc., 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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Yes, There is Such a Thing Called Apparent Authority

Posted by David Adelstein on March 04, 2018
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“But he did NOT have the authority….”   This is the beginning of a sentence that does not start well.  

Agents have the authority to bind their principal.  “Even where there is no express agent/principal relationship, a principal may be bound by the acts of an agent acting with apparent authority.”  Clayton v. Poggendorf, 43 Fla.L.Weekly D436a (Fla. 4th DCA 2018). 

Apparent authority sometimes gets lost in the shuffle and the reason why the sentence, “But he did not have the authority…,” does not start well.  If the person is deemed to have apparent authority then he did have the authority to bind you or make decisions on your behalf.

Apparent authority arises from the authority a principal knowingly tolerates or allows an agent to assume, or which the principal by this actions or words holds the agent out as possessing.”  Clayton, supra.  If the principal creates the appearance of the agent’s authority, then the agent will have apparent authority.  Id quoting Regions Bank v. Maroone Chevrolet, L.L.C., 118 So.3d 251, 255 (Fla. 3d DCA 2013).

In Clayton, a settlement agreement with installment payments was entered into.  The settlement agreement provided that if payments were not timely made, the payee would provide the payor a notice to cure.  If there was no cure, the payee could move for a judgment against the payor.  These are common settlement terms when dealing with installment payments.  

In this case, notices to cure were sent to the payor’s counsel when the payor failed to timely pay.  The payee’s counsel even inquired whether the payor’s counsel was still representing the payor and no response was ever provided.  In prior instances, the payor cured the nonpayment after his counsel received the notice to cure.  However, when the payor ultimately did not cure, the payee moved for a judgment against the payor per the terms of the settlement agreement.  The payor argued that the notices to cure should not have been sent to his counsel because his counsel did not have the authority. This was not a successful argument:

Apparent authority rests on the doctrine of estoppel. Estoppel requires: 1) representation of a material fact by the party estopped (Clayton) [payor] to the party claiming the estoppel (Poggendorf and Thomas) [payee] that is contrary to the fact later asserted by the estopped party; 2) reliance on that representation by the party claiming the estoppel; and 3) the party claiming estoppel detrimentally changed their position due to such reliance.  Clayton [payor], by his conduct in allowing Tittle [payor’s attorney] to accept the notices of default, represented that the notices of default complied with the Settlement Agreement. Poggendorf and Thomas [payee] clearly relied on that representation by continuing to send the email notices to Tittle. Finally, Poggendorf and Thomas changed their position by not sending the notices directly to Clayton.

So, yes, apparent authority does exist!

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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Defamation Per Se Opens Door for Punitive Damages

Posted by David Adelstein on February 18, 2018
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A defamation per se action opens the door for punitive damages even if actual damages cannot be shown or proven.  Lawnwood Medical Center, Inc. v. Sadow, 43 So.3d 710, 729 (Fla. 4th DCA 2010).   This is because malice is presumed and, thus, the statements are presumed harmful as a matter of law.  Id.  However, “proof of liability for defamation per se requires a showing that the declarant knew or should have known the defamatory statement was not true.”  Tilton v. Wrobel, 198 So.3d 909 (Fla. 4th DCA 2016).  Hence, while a claimant may not be able to prove actual damages as the result of the defamatory (slanderous or libelous) per se action, the plaintiff can still potentially recover punitive damages.  It is this reason why parties oftentimes pursue defamation per se actions.

 “‘[A] publication is libelous per se, or actionable per se, if, when considered alone without innuendo: (1) it charges that a person has committed an infamous crime; (2) it charges a person with having an infectious disease; (3) it tends to subject one to hatred, distrust, ridicule, contempt, or disgrace; or (4) it tends to injure one in his trade or profession.’” Blake v. Guistibelli, 182 So.3d 881, 884 (Fla. 4th DCA 2016) quoting Richard v. Gray, 62 So.2d 597, 598 (Fla. 1953).

Libel concerns the written publication of false statements.  Dunn v. Air Line Pilots Ass’n, 193 F.3d 1185, 1191 (11th Cir. 1999)

Slander is a spoken or oral defamation of another which is published to others and which tends to damage that person’s reputation, ability to conduct that person’s business or profession, and which holds that person up to disgrace and humiliation.”  Scott v. Busch, 907 So.2d 662, 666 (Fla. 5th DCA 2005).

There is a lot more to defamation and if you have been the victim of a truly defamatory per se action, consult with counsel so that you understand your rights moving forward.

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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