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West American Insurance Co. v. Neva Products, Inc.

Citations: 490 So. 2d 117; 11 Fla. L. Weekly 1046; 1986 Fla. App. LEXIS 7606Docket: No. 86-446

Court: District Court of Appeal of Florida; May 2, 1986; Florida; State Appellate Court

Narrative Opinion Summary

The petition for writ of certiorari is granted, and the previous order requiring the petitioner to produce portions of its claim file and related records dated prior to the lawsuit is quashed. The ruling is based on precedents, particularly Florida Cypress Gardens, Inc. v. Murphy, which established that an insurer's accident investigation file is considered work product, regardless of whether it was created before the lawsuit was filed. Other supporting cases include Seaboard Air Line Railroad v. Timmons and various decisions involving Winn-Dixie Stores, which reinforce the work product doctrine. The court acknowledges that some parts of the order in question do not pertain to work product and instructs the trial court to issue an amended order that aligns with this ruling. The opinion is concurred by Justices Grimes, Lehan, and Frank.

Legal Issues Addressed

Clarification of Non-Work Product Material

Application: The court instructed the trial court to amend its order to correctly identify and exclude non-work product materials, ensuring compliance with the work product doctrine.

Reasoning: The court acknowledges that some parts of the order in question do not pertain to work product and instructs the trial court to issue an amended order that aligns with this ruling.

Judicial Review of Discovery Orders

Application: The court quashed the previous order that required the production of certain documents, indicating that the trial court erred in its determination of what constitutes work product.

Reasoning: The petition for writ of certiorari is granted, and the previous order requiring the petitioner to produce portions of its claim file and related records dated prior to the lawsuit is quashed.

Work Product Doctrine

Application: The court recognizes that an insurer's accident investigation file is protected as work product, even if it was created before the initiation of a lawsuit.

Reasoning: The ruling is based on precedents, particularly Florida Cypress Gardens, Inc. v. Murphy, which established that an insurer's accident investigation file is considered work product, regardless of whether it was created before the lawsuit was filed.