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MERCEDES SANCHEZ v. MAC ACQUISITION, LLC, etc.

Citation: Not availableDocket: 20-0639

Court: District Court of Appeal of Florida; August 25, 2021; Florida; State Appellate Court

Original Court Document: View Document

Narrative Opinion Summary

The Third District Court of Appeal of Florida reviewed the case of Mercedes Sanchez, et al. vs. MAC Acquisition, LLC, et al., which originated from the Circuit Court for Miami-Dade County. The primary legal issue centered on premises liability, specifically whether liability for injuries due to dangerous conditions on a property is determined by the right to control access or legal ownership. The appellate court affirmed the lower court's decision, which was based on the established legal principle that control, rather than ownership, defines liability. Control is characterized by the ability to manage or exclude others from the premises, typically falling to the lessee in lease agreements. In this case, the court found that the lessee had actual possession and control over the property, not the lessor, thus absolving the lessor of liability. The court referenced precedents such as Bovis v. 7-Eleven, Inc. and Bechtel Corp. v. Batchelor to support its conclusion, ultimately reinforcing the premises liability framework and confirming the lower court's judgment.

Legal Issues Addressed

Affirmation of Lower Court's Decision

Application: The appellate court affirmed the lower court's ruling, supporting established principles of premises liability as applied to the case facts.

Reasoning: Consequently, the court affirmed the lower court's ruling, emphasizing the established principles of premises liability.

Control Defined in Premises Liability

Application: The court explained that control is defined as the ability to manage or exclude others from the premises, which is typically the responsibility of the entity in possession, usually the lessee.

Reasoning: The ruling cites precedent indicating that control is defined as the ability to manage or exclude others from the premises, highlighting that this duty typically lies with the entity in possession of the property, which, in lease agreements, is usually the lessee.

Lessor's Lack of Control

Application: In this case, the court determined that the lessor did not have the right to control access to the premises, as the lessee held actual possession and control.

Reasoning: In this instance, the court found that the lessor did not have the right to control access to the leased premises, as the lessee had actual possession and control.

Premises Liability and Control

Application: The court affirms that liability for injuries due to dangerous conditions on a property is based on the right to control access rather than legal ownership.

Reasoning: The court confirmed that liability for injuries resulting from dangerous conditions on a property is determined by the right to control access to that property rather than legal ownership.