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Shands Teaching Hospital & Clinics, Inc. v. Samuel

Citations: 926 So. 2d 441; 2006 Fla. App. LEXIS 5413Docket: Nos. 1D05-5186, 1D05-5774 to 1D05-5782, 1D05-5785 to 1D05-5787

Court: District Court of Appeal of Florida; April 13, 2006; Florida; State Appellate Court

Narrative Opinion Summary

In this consolidated case, Shands Teaching Hospital and Climes, Inc. sought writs of prohibition after their motions to disqualify a trial judge were denied. Initially, in a medical negligence trial against Shands, the trial judge exhibited concerns over the litigation tactics of Shands and the University of Florida Board of Trustees, suggesting bias across all cases involving these parties. Shands managed to disqualify the judge in the specific Dunn v. Shands Teaching Hospital case due to this perceived bias. However, motions to disqualify the judge in related cases were denied, considered legally insufficient by the trial judge. The appellate court, referencing Walls v. State, determined that the trial judge's acknowledgment of bias necessitated disqualification across similar cases, contrasting with the precedent of City of Hollywood v. Witt, which was found inapplicable due to differing circumstances. As a result, the appellate court granted the writs of prohibition, mandating the assignment of a new judge for future proceedings. The decision was unanimously concurred by Judges Ervin, Davis, and Benton.

Legal Issues Addressed

Conditions for Granting Writ of Prohibition

Application: A writ of prohibition was granted when motions to disqualify a judge were denied despite the judge's acknowledgment of bias.

Reasoning: Consequently, the petitions for writ of prohibition were granted, and a new judge will be assigned for further proceedings in these cases.

Disqualification of Judge Due to Perceived Bias

Application: The trial judge's acknowledgment of bias in one case necessitated disqualification in other cases involving the same parties.

Reasoning: The court found that the trial judge erred in denying these motions, referencing the precedent set in Walls v. State, where a judge’s prior acknowledgment of bias in one case necessitated disqualification in others with similar circumstances.

Misapplication of Precedent

Application: The trial judge's reliance on City of Hollywood v. Witt was deemed misplaced in assessing the sufficiency of evidence for bias.

Reasoning: The trial judge's reliance on City of Hollywood v. Witt was deemed misplaced; while that case involved insufficient evidence of bias extending to other cases, here the judge had explicitly acknowledged concerns that spanned all cases involving Shands and the Board.