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Harris v. Anne Bates Leach Eye Institute

Citations: 206 So. 3d 800; 2016 Fla. App. LEXIS 16676Docket: No. 3D16-257

Court: District Court of Appeal of Florida; November 8, 2016; Florida; State Appellate Court

Narrative Opinion Summary

James S. Harris appeals the trial court's denial of his rule 1.540(b) motion to vacate the dismissal of his medical malpractice complaint, which was rendered with prejudice on August 29, 2012. The court affirmed the denial, noting that Harris's motion was untimely. Although Harris claimed he did not initially receive the dismissal order, he acknowledged having a copy by February 23, 2014. Since his motion to vacate was filed more than one year after he received the order, it was deemed untimely according to precedent. The trial court's decision to deny the motion to vacate was therefore upheld.

Legal Issues Addressed

Dismissal with Prejudice

Application: The original dismissal of the medical malpractice complaint was with prejudice, which impacts the appellant's ability to refile the case.

Reasoning: James S. Harris appeals the trial court's denial of his rule 1.540(b) motion to vacate the dismissal of his medical malpractice complaint, which was rendered with prejudice on August 29, 2012.

Effect of Lack of Initial Notice

Application: The appellant's claim that he did not initially receive the dismissal order did not affect the ruling because he acknowledged having received it at a later date.

Reasoning: Although Harris claimed he did not initially receive the dismissal order, he acknowledged having a copy by February 23, 2014.

Timeliness of Rule 1.540(b) Motion

Application: The court determined that the motion to vacate was untimely because it was filed more than one year after the appellant admitted to having received the dismissal order.

Reasoning: Since his motion to vacate was filed more than one year after he received the order, it was deemed untimely according to precedent.