SAP AMERICA, INC., PETITIONER,
v.
ROYAL FLOWERS, INC., RESPONDENT
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The appellate court denied SAP America's petition to quash an order allowing Royal Flowers to amend its complaint to seek punitive damages. The court held that while it has certiorari jurisdiction to review procedural compliance for punitive damages claims, it cannot review the sufficiency of the evidence presented to the trial court.
No, an appellate court lacks certiorari jurisdiction to review the sufficiency of the evidence supporting a trial court's decision to grant leave to amend a complaint to add a claim for punitive damages, provided the trial court has followed the procedural requirements.
[1] Certiorari is an appropriate remedy to challenge a trial court's order allowing a punitive damages claim to proceed when the procedural requirements of section 768.72, Fl…
[2] An appellate court lacks certiorari jurisdiction to review the sufficiency of the evidence considered by the trial court in granting leave to amend a complaint to add a c…
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Join FLexlaw to unlock all legal intelligence“Although it is clear that certiorari relief is an appropriate remedy to challenge a trial court’s order allowing a punitive damages claim to proceed when the procedural requirements of section 768.72, Florida Statutes (2015), have not been followed, see Globe Newspaper Co. v. King, 658 So. 2d 518, 520 (Fla.1995); Coronado Condo. Ass’n v. La Corte, 103 So. 3d 239, 240 (Fla. 3d DCA 2012), it is equally clear that an appellate court lacks certiorari jurisdiction to review the sufficiency of the evidence considered by the trial court in granting leave to amend the complaint to add a claim for punitive damages.”
Establishes the scope of certiorari review regarding punitive damages claims and the court's inability to review the sufficiency of evidence.
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Join FLexlaw to unlock all legal intelligenceRoyal Flowers moved to amend its complaint to assert a claim for punitive damages after obtaining summary judgment on its breach of contract claim. Th…
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SAP America, Inc. (“SAP”) petitions this Court seeking quashal of the trial court’s order granting Royal Flowers, Inc.’s (“Royal Flowers”) motion for leave to amend its complaint to assert a claim for punitive damages. ' Although it is clear that certiorari relief is an appropriate remedy to challenge a trial court’s order allowing a punitive damages claim to proceed when the procedural requirements of section 768.72, Florida Statutes (2015), have not been followed, see Globe Newspaper Co. v. King, 658 So.2d 518, 520 (Fla.1995); Coronado Condo. Ass’n v. La Corte, 103 So.3d 239, 240 (Fla. 3d DCA 2012), it is equally clear that an appellate court lacks certiorari jurisdiction to review the sufficiency of the evidence considered by the trial court in granting leave to amend the complaint to add a claim for punitive damages. Globe, 658 So.2d at 520; Ross Dress for Less Virginia, Inc. v. Castro, 134 So.3d 511, 525 (Fla. 3d DCA 2014).
The record reflects that- after the trial court granted Royal Flowers’ motion for summary judgment as to its breach of contract claim, Royal Flowers t moved for leave to amend its complaint to seek punitive damages in connection to its fraud in the inducement claims. The motion was fully briefed and the trial court conducted a special set hearing where Royal Flowers made an evidentiary proffer in support of *947its motion. Thereafter, the trial -court entered an order that was deficient, but later entered a corrected order granting Royal Flowers’ motion to amend its complaint to add a claim for punitive damages. In its corrected order, the trial court found that Royal Flowers had presented “a reasonable evidentiary basis for recovery of punitive damages” as “set forth in the Motion and argued at the hearing conducted on November 4, 2015 and as reflected in the transcript incorporated -and adopted herein.”
Because the trial court complied with the procedural requirements of section 768.72, and we are not permitted to review the sufficiency of the evidence on certiorari review, we deny SAP’s petition.
Petition denied.
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Birdie M. Varnedore, M.D. v. Copeland, 210 So. 3d 741 (Fla. 5th DCA 2017)…uired to make an affirmative finding that plaintiff has made a “reasonable showing by evidence,” which would provide a “reasonable evidentiary basis for recovering such damages” if the motion to amend is granted. SAP Am. Inc. v. Royal Flowers, Inc., 187 So. 3d 946, 947 (Fla. 3d DCA 2016); see also Petri Positive Pest Control, Inc. v. CCM Condo. Ass’n, 174 So. 3d 1122, 1122 (Fla. 4th DCA 2015); Royal Caribbean Cruises, Ltd. v. Doe, 44 So. 3d 230, 235-36 (Fla. 3d DCA 2010); Henn, 589 So. 2d at 1335. We agree th…
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Levin v. Pritchard, 258 So. 3d 545 (Fla. 3d DCA 2018)…ver, we are not permitted "to review the sufficiency of the evidence considered by the trial court in granting leave to amend the complaint to add a claim for punitive damages." Robins, 253 So. 3d at 96 (quoting SAP Am., Inc. v. Royal Flowers, Inc., 187 So. 3d 946 (Fla. 3d DCA 2016) ); see also Globe, 658 So. 2d at 520. Finally, certiorari relief is only appropriate "when the record establishes that a trial court applied the incorrect law; certiorari relief is not available to remedy an incorrect application…
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Robins v. Colombo, 253 So. 3d 94 (Fla. 3d DCA 2018)
Previewing 3 of 5 citing cases — full citator treatment, depth of discussion, and citing context are member features.
Join FLexlaw to unlock all legal intelligenceAuthorities Cited
- Globe Newspaper Co. v. King, 658 So. 2d 518 (Fla. 1995)
- Ross Dress FOR Less Va., Inc. v. Castro, 134 So. 3d 511 (Fla. 3d DCA 2014)
- Coronado Condo. Ass'n, Inc. v. Rocque La Corte, 103 So. 3d 239 (Fla. 3d DCA 2012)