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Otis Elevator Co. v. Gerstein

Citations: 612 So. 2d 659; 1993 Fla. App. LEXIS 155; 1993 WL 8894Docket: No. 92-2445

Court: District Court of Appeal of Florida; January 18, 1993; Florida; State Appellate Court

Narrative Opinion Summary

The case involved a personal injury lawsuit filed by Jimmie Frazier against Otis Elevator Company following an accident with an industrial lift truck. After a jury ruled in favor of Frazier, Otis Elevator Company filed post-trial motions, including a motion for judgment and a motion for a new trial. The original judge, Judge Nadler, recused himself without ruling on these motions, as did the subsequent judge, Judge Henderson. The case was ultimately assigned to Judge Gerstein, who expressed doubts about his authority to decide the pending motions. Otis sought a writ of mandamus from the appellate court to compel a ruling. The appellate court, relying on precedents, determined that a successor judge is authorized to rule on motions for a new trial in jury cases. As a result, the court granted Otis's petition for a writ of mandamus, directing the trial court to rule on the merits of Otis's post-trial motions. The court dismissed any contrary interpretations from previous cases as dictum, thereby clarifying the authority of successor judges in such matters.

Legal Issues Addressed

Authority of Successor Judge to Rule on Post-Trial Motions

Application: The appellate court concluded that a successor judge has the authority to rule on motions for a new trial in jury cases, thereby granting Otis's petition for a writ of mandamus.

Reasoning: The appellate court, referencing precedents from the Florida Supreme Court and its own prior decisions, concluded that a successor judge is indeed authorized to rule on motions for a new trial in jury cases.

Issuance of Writ of Mandamus

Application: The court issued a writ of mandamus to compel the trial court to decide on the post-trial motions filed by Otis Elevator Company, emphasizing the successor judge's authority.

Reasoning: Consequently, the court granted Otis's petition and issued a writ of mandamus instructing the trial court to rule on the merits of the pending motions.