Narrative Opinion Summary
This case involves the personal representative of an estate against a school board and its officials concerning the allocation of fault under Florida’s comparative fault statute, Fla. Stat. Ann. 768.81. The central legal issue was whether liability should be apportioned between negligent and intentional tortfeasors. Initially, the Eleventh Circuit sought guidance from the Florida Supreme Court, but subsequently withdrew its request after pertinent decisions in Merrill Crossings Assoc. v. McDonald and Stellas v. Alamo Rent-A-Car clarified the matter. The trial court's decision excluded the decedent from the verdict form on the basis that his action was intentional, which aligned with the clarified interpretation of the statute. The Eleventh Circuit affirmed the district court's judgment, siding with the trial court's approach and concluding the case. This outcome confirmed that under Florida statute, intentional tortfeasors are excluded from liability apportionment, resolving the issues presented in the appeals.
Legal Issues Addressed
Allocation of Fault under Florida's Comparative Fault Statutesubscribe to see similar legal issues
Application: The court addressed the issue of whether fault should be allocated between negligent and intentional tortfeasors under Florida law.
Reasoning: The Eleventh Circuit addressed appeals concerning the allocation of fault under Florida’s comparative fault statute, Fla. Stat. Ann. 768.81.
Certification of Legal Questions to State Supreme Courtssubscribe to see similar legal issues
Application: The Eleventh Circuit withdrew its certification to the Florida Supreme Court after relevant precedents provided clarity on the issue.
Reasoning: Following the Supreme Court's decisions in Merrill Crossings Assoc. v. McDonald and Stellas v. Alamo Rent-A-Car, which clarified the issue, the Eleventh Circuit withdrew its certification.
Exclusion of Intentional Tortfeasor from Liability Allocationsubscribe to see similar legal issues
Application: The trial court excluded the decedent from the verdict form, as his action was deemed intentional, preventing liability apportionment under the clarified statute.
Reasoning: The trial court had determined that Shawn David Wyke's name should not be included on the verdict form because he had committed an intentional act (suicide), not a negligent one, thereby precluding the jury from apportioning liability to him.