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Smith v. Holy Temple Church of God in Christ, Inc.

Citations: 566 So. 2d 864; 1990 Fla. App. LEXIS 6749; 1990 WL 129102Docket: 89-1873

Court: District Court of Appeal of Florida; September 5, 1990; Florida; State Appellate Court

Narrative Opinion Summary

In this case, the appellant was involved in a car accident with a vehicle owned by the appellee, resulting in a jury awarding her $300,000 in damages but attributing 80% of the fault to her for not wearing a seat belt. The appellant contended that the jury should not have been instructed on the seat belt defense due to insufficient evidence of the seat belt's operability. The appellate court agreed, finding that the appellee failed to present competent evidence that the seat belt was functional and that its nonuse contributed to the damages. The court highlighted that there was no indication of the seat belt being operational, such as evidence of it clicking or being securely anchored. Consequently, the appellate court reversed the trial court's judgment, remanding the case to enter judgment for the full amount of the jury's verdict in favor of the appellant. The court also dismissed the appellee's cross-appeal, affirming it as without merit, with Judges Wigginton and Allen concurring in the decision.

Legal Issues Addressed

Burden of Proof for Seat Belt Operability

Application: The court emphasized that the defendant failed to meet the burden of proof regarding the seat belt's operability, thus rendering the seat belt defense inappropriate in this case.

Reasoning: The court agreed with Smith, noting that while there was a seat belt present, there was no evidence showing it was operational.

Reversal of Judgment for Improper Jury Instruction

Application: The appellate court reversed the trial court's judgment due to the improper jury instruction on the seat belt defense, as there was no evidence of the seat belt's operability.

Reasoning: Consequently, the appellate court reversed the trial court's judgment and remanded the case with directions to enter a judgment for Smith for the full amount of the jury's verdict.

Seat Belt Defense in Personal Injury Cases

Application: The court held that the seat belt defense is invalid without competent evidence demonstrating the seat belt's operability and its contribution to the plaintiff's damages.

Reasoning: The appellate court referenced prior cases to clarify that for a seat belt defense to be valid, the defendant must provide competent evidence indicating that the seat belt was operational and that its nonuse contributed to the damages.