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Bravo Electric Co. v. Carter Electric Co.

Citations: 532 So. 2d 698; 13 Fla. L. Weekly 2062; 1988 Fla. App. LEXIS 3872; 1988 WL 89694Docket: No. 87-667

Court: District Court of Appeal of Florida; September 1, 1988; Florida; State Appellate Court

Narrative Opinion Summary

In this case, Bravo Electric Company appealed a partial summary judgment that held it liable for attorney fees and costs incurred by Carter Electric Company during a negligence suit. The plaintiff alleged Bravo was actively negligent and Carter vicariously liable. Carter's insurer requested that Bravo indemnify and defend Carter, but Bravo's insurer declined, leading Carter's insurer to independently manage the defense. The trial court ruled in favor of Carter, affirming Bravo's responsibility for indemnification under common law principles. On appeal, Bravo did not contest the judgment on the basis of fundamental error, instead arguing that Carter's counsel's closing arguments were prejudicial, a contention the appellate court deemed irrelevant to the indemnity issue. The judgment was affirmed, with one judge concurring and another dissenting, leaving Bravo responsible for the legal costs and fees incurred by Carter. This case underscores the binding nature of indemnification obligations in the context of joint liability for negligence.

Legal Issues Addressed

Appeal and Fundamental Error

Application: Bravo Electric Company's appeal did not address any fundamental error, which potentially limited the scope of review, as their focus was on the closing argument by Carter's counsel rather than the indemnity issue.

Reasoning: Bravo did not raise the dissenting argument regarding fundamental error on appeal.

Indemnification under Common Law

Application: The court applied common law principles of indemnity to affirm that Bravo Electric Company was liable for attorney fees and costs incurred by Carter Electric Company, as Carter was defending a negligence action where Bravo was allegedly actively negligent.

Reasoning: Carter’s insurer demanded that Bravo provide a defense and indemnify Carter for costs, but Bravo's insurer denied the request, despite it being supported by common law indemnity principles.

Relevance of Trial Arguments in Indemnity Claims

Application: The court found Bravo's claim regarding Carter's trial counsel's closing argument to be irrelevant to the indemnification dispute, reinforcing that such arguments do not affect the underlying indemnity obligations.

Reasoning: Bravo's appeal focused on a claim that Carter's trial counsel's closing argument harmed its interests, which the court found irrelevant to the indemnification matter between the parties.