Narrative Opinion Summary
This case involves a negligence lawsuit brought by an individual against sand manufacturers, alleging the development of silicosis due to exposure to silica dust from sandblasting activities between 1972 and 1974. The manufacturers invoked the statute of repose under section 95.031(2) of the Florida Statutes, which bars claims filed more than twelve years after the sale of the product. Initially, the trial court granted summary judgment for the manufacturers, but this decision was reversed on appeal. The Florida Supreme Court had previously declared this statute unconstitutional in related cases due to its potential to bar claims before an injury is recognizable, but later upheld its constitutionality under different circumstances. The appellate court identified the timing of the plaintiff's illness manifestation as a factual issue, making summary judgment inappropriate. The court's decision was influenced by prior rulings that distinguished between the products liability context and medical malpractice, emphasizing the need for awareness of a causal link for a claim to accrue. The case was remanded for further proceedings, highlighting ongoing legal debates over the statute's application, particularly where delayed injury manifestation is concerned.
Legal Issues Addressed
Accrual of Cause of Actionsubscribe to see similar legal issues
Application: A cause of action accrues when the plaintiff becomes aware or should be aware of the causal connection between the injury and the product.
Reasoning: Manifestation occurs when a plaintiff is on notice of a causal relationship. This determination is generally a jury question.
Constitutionality of Statute of Reposesubscribe to see similar legal issues
Application: The Supreme Court upheld the statute of repose as constitutional, affirming that it does not infringe on the Florida Constitutional right of access to courts.
Reasoning: The Supreme Court upheld the trial court's summary judgment in favor of the manufacturer, affirming that section 95.031(2) does not infringe on the Florida Constitutional right of access to courts.
Delayed Injury Manifestationsubscribe to see similar legal issues
Application: The court acknowledged that delayed manifestation of injury can complicate the application of the statute of repose, requiring distinct treatment in specific cases.
Reasoning: The Corcoran court reaffirmed the viability of Diamond, stating that no Supreme Court decision post-Pullum has negated its principles.
Statute of Repose in Products Liabilitysubscribe to see similar legal issues
Application: The statute bars claims filed more than twelve years after the product was sold, unless the injury was not recognizable within that period due to delayed manifestation.
Reasoning: The statute barred claims filed more than twelve years after the product was sold or the fraud occurred.
Summary Judgment in Products Liability Casessubscribe to see similar legal issues
Application: Summary judgment may be improper if the timing of injury manifestation presents a factual issue.
Reasoning: The court found that the timing of Barnes' illness manifestation was a factual issue, rendering the grant of summary judgment improper.