LORIE A. WHITE
v.
CLYDE S. EVANS

Fla. 5th DCA | 2026-06-19
No. 2025-0198
Falvey, J., Lambert, J., Soud, J., Boatwright, J.
2026 FL 7605 Florida District Court of Appeal, Fifth District (2026)

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Holding

A trial court errs in directing a verdict on causation in a negligence case even when the defendant concedes negligence, as directed verdicts in negligence cases are rarely appropriate.


Headnotes

[1] Directed verdicts on the issue of causation in negligence cases are rarely appropriate and should not be granted even when a defendant concedes negligence.

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Key Quotes

“recognizing that directed verdicts in negligence cases are rarely appropriate”

Citation to Lancheros v. Burke, 375 So. 3d 927, 929 (Fla. 6th DCA 2023)

Facts & Procedural History

Clyde Evans brought a motor vehicle negligence action against Lorie White. White conceded that her negligence caused the subject motor vehicle acciden…

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Opinion of the Court

FIFTH DISTRICT COURT OF APPEAL

STATE OF FLORIDA

LORIE A. WHITE, Appellant,

v.

CLYDE S. EVANS, Appellee.

Case No. 5D2025-0198 LT Case No. 2020-CA-000401-A

On appeal from the Circuit Court for Citrus County. Carol A. Falvey, Judge.

Rhonda B. Boggess, of Marks Gray, P.A., Jacksonville, for Appellant.

Brian J. Lee, of Morgan & Morgan, Jacksonville, for Appellee.

June 19, 2026

PER CURIAM.

Lorie White appeals the final judgment for damages entered against her and in favor of Clyde Evans after the jury trial held on Evans's motor vehicle negligence action. White argues that while she conceded that her negligence caused the subject motor vehicle accident, the trial court thereafter erred in directing a verdict on the issue of causation. We agree. See Lancheros v. Burke, 375 So. 3d 927, 929 (Fla. 6th DCA 2023) (recognizing that directed verdicts in negligence cases are rarely appropriate).

Accordingly, we reverse the final judgment and remand for a new trial.

REVERSED AND REMANDED.

LAMBERT, SOUD, and BOATWRIGHT, JJ., concur.


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