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City Provisioners, Inc. v. Anderson

Citations: 578 So. 2d 855; 1991 Fla. App. LEXIS 3933; 1991 WL 66665Docket: 90-1047

Court: District Court of Appeal of Florida; May 2, 1991; Florida; State Appellate Court

Narrative Opinion Summary

In this appellate case, City Provisioners, Inc. and Charley Dale Miller challenged a judgment favoring Richard W. Anderson following a personal injury lawsuit arising from an automobile accident. The central issue on appeal was the propriety of the closing arguments made by the plaintiff's counsel. The counsel's remarks improperly suggested that the jury's verdict could be adjusted by the judge, misleadingly referencing Florida's laws on remittitur and additur. Furthermore, the counsel appealed to the jury's sympathy using personal anecdotes and referenced facts not in evidence. Although objections were raised, the trial judge dismissed them as mere arguments, and the motion for a mistrial was denied. The appellate court found these remarks cumulatively biased the jury's deliberations, thus necessitating a new trial. However, given the strong evidence supporting the liability determination, the new trial was limited to the issue of damages. The appellate court affirmed the liability finding, reversed the damages award, and remanded the case for further proceedings concerning damages. The appellee's motion for attorney's fees was also denied as premature.

Legal Issues Addressed

Denial of Attorney's Fees

Application: The appellate court denied the appellee's motion for attorney's fees as it was considered premature.

Reasoning: The court also denied the appellee's motion for attorney's fees as premature.

Improper Closing Arguments

Application: The appellate court found that the plaintiff's counsel's remarks during closing arguments improperly influenced the jury, warranting a new trial on damages only.

Reasoning: Improper remarks made by the plaintiff's counsel during closing arguments, while individually insufficient to reverse the jury's verdict, cumulatively affected the jury's deliberations, necessitating a new trial.

Limitation of New Trial to Damages

Application: The appellate court limited the new trial to the issue of damages due to the strong evidence supporting the jury's liability finding.

Reasoning: The appellate court determined that due to the significant number and nature of these comments, the appellant is entitled to a new trial; however, because the jury's liability finding was strongly supported by evidence and most improper comments pertained to damages, the new trial will be limited to the damages aspect only.

Objections During Closing Arguments

Application: Despite objections to the plaintiff's counsel's arguments, the trial judge ruled them as mere 'argument,' and denied a motion for mistrial.

Reasoning: Despite objections made during closing arguments, the trial judge ruled them as mere ‘argument,’ and a subsequent motion for mistrial was denied.

Remittitur and Additur Misinterpretation

Application: The plaintiff's counsel misinformed the jury regarding the possibility of the judge adjusting their verdict, which is contrary to Florida law.

Reasoning: The plaintiff's counsel incorrectly suggested that the jury could have their verdict adjusted by the judge, a misinterpretation of Florida law on remittitur and additur, which was deemed inappropriate for closing arguments.