UNITED AUTOMOBILE INSURANCE COMPANY,
v.
BEST AMERICAN DIAGNOSTIC CENTER, INC. A/A/O JORGE L. FERNANDEZ,

Fla. 3d DCA | 2022-03-16
No. 21-0319
Harris, J., Logue, J., Hendon, J., Lobree, J.
Florida District Court of Appeal, Third District (2022)

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Holding

Collateral estoppel does not apply when a party's identity changes from case to case based on different assignors, as the identity element of collateral estoppel is not satisfied.


Headnotes

[1] Collateral estoppel requires identity of parties, and this element is not satisfied when a defendant's legal identity is derived from different assignors in separate case…

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Key Quotes

“Millennium's 'identity' is not the same in each of these cases against United Auto; Millennium draws its identity from its assignor from case to case. The identity element of collateral estoppel, therefore, is not satisfied.”

The court's explanation of why collateral estoppel does not apply when a party's identity varies based on its assignor.

Facts & Procedural History

United Automobile Insurance Company appealed a county court decision involving Best American Diagnostic Center, Inc., a/a/o Jorge L. Fernandez. The ca…

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Opinion of the Court
Lobree

Third District Court of Appeal State of Florida

Opinion filed March 16, 2022. Not final until disposition of timely filed motion for rehearing.

________________

No. 3D21-319 Lower Tribunal Nos. 20-273 AP, 11-27644 SP ________________

United Automobile Insurance Company, etc., Appellant,

vs.

Best American Diagnostic Center, Inc., a/a/o Jorge L. Fernandez, Appellee.

An Appeal from the County Court for Miami-Dade County, Ayana Harris, Judge.

Michael J. Neimand, for appellant.

David B. Pakula, P.A., and David B. Pakula (Pembroke Pines); and Marks & Fleischer, P.A., and Gary Marks (Fort Lauderdale), for appellee.

Before LOGUE, HENDON, and LOBREE, JJ.

PER CURIAM.

Reversed and remanded.

Footnotes
2 We reverse and remand consistent with our recent decision in United Automobile Insurance Co. v. Millennium Radiology, LLC, 47 Fla. L. Weekly D175 (Fla. 3d DCA Jan. 12, 2022) (“Millennium’s ‘identity’ is not the same in each of these cases against United Auto; Millennium draws its identity from its assignor from case to case. The identity element of collateral estoppel, therefore, is not satisfied.”).

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