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Lee v. Hollywood Car & Truck Rental, Inc.

Citations: 485 So. 2d 843; 11 Fla. L. Weekly 564; 1986 Fla. App. LEXIS 6704Docket: No. 84-2393

Court: District Court of Appeal of Florida; March 4, 1986; Florida; State Appellate Court

Narrative Opinion Summary

In a case involving Sheila Lee and Hollywood Car and Truck Rental, Inc., the plaintiff filed a lawsuit for personal injuries sustained from a vehicle fire. The trial court issued a directed verdict in favor of the defendant, citing insufficient evidence concerning the cause of the fire. Lee appealed this decision. On appeal, the court reversed the trial court's ruling, recognizing that Lee could invoke the doctrine of res ipsa loquitur, which suggests negligence by the defendant given the circumstances of the incident. The vehicle, rented by Lee for a week, caught fire unexpectedly while she was driving, resulting in severe burns for Lee. The appellate court noted that Lee neither knew the fire's origin nor contributed to its cause. Consequently, the appellate court concluded that the presumption of negligence was sufficient to warrant a new trial, and thus remanded the case for further proceedings. The decision to reverse and remand was unanimous among the judges, aligning with established precedents.

Legal Issues Addressed

Application of the Doctrine of Res Ipsa Loquitur

Application: The appellate court determined that the plaintiff could invoke the doctrine of res ipsa loquitur, which implies negligence by the defendant, Hollywood Car and Truck Rental, Inc., due to the circumstances of the fire.

Reasoning: The court determined that, based on the circumstances, Lee could invoke the doctrine of res ipsa loquitur, which implies negligence on the part of Hollywood Rental.

Directed Verdict and Sufficiency of Evidence

Application: The trial court's granting of a directed verdict in favor of Hollywood Rental was overturned by the appellate court due to insufficient consideration of the evidence under the doctrine of res ipsa loquitur.

Reasoning: The appellate court reversed the trial court's decision and remanded the case for a new trial. It noted that Lee had rented the vehicle for seven days when it unexpectedly caught fire.

Reversal and Remand for New Trial

Application: The appellate court reversed the trial court's directed verdict and remanded the case for a new trial, finding that the presumption of negligence warranted further proceedings.

Reasoning: The appellate court reversed the trial court's decision and remanded the case for a new trial.