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Merastar Insurance Co. v. Webb

Citations: 932 So. 2d 228; 2005 Fla. App. LEXIS 14136Docket: Nos. 4D04-1342, 4D04-2501

Court: District Court of Appeal of Florida; September 7, 2005; Florida; State Appellate Court

Narrative Opinion Summary

The trial court's decision to deny the appellant's motions for mistrial and new trial based on certain improper comments made during closing arguments is affirmed, as these comments were not deemed prejudicial enough to warrant such drastic measures. However, the trial court erred by admitting previously undisclosed evidence regarding the plaintiff's prescription drug bills, which could have influenced the jury's verdict. This aligns with precedent that prohibits the introduction of undisclosed evidence that suggests new theories of damages. As a result, the case is remanded for the trial court to grant a remittitur for the amount related to the prescription drug bills. The judgment in favor of Webb is affirmed, except for the prescription drug bills, and the judgment taxing costs against the appellant is also affirmed. The decision is affirmed in part, reversed in part, and remanded.

Legal Issues Addressed

Admission of Undisclosed Evidence

Application: The trial court's error in admitting previously undisclosed evidence about the plaintiff's prescription drug bills necessitated a remittitur, as it could have impacted the jury's verdict.

Reasoning: However, the trial court erred by admitting previously undisclosed evidence regarding the plaintiff's prescription drug bills, which could have influenced the jury's verdict.

Denial of Motions for Mistrial and New Trial

Application: The court evaluated whether improper comments during closing arguments warranted a mistrial or new trial and concluded they were not prejudicial enough to justify such measures.

Reasoning: The trial court's decision to deny the appellant's motions for mistrial and new trial based on certain improper comments made during closing arguments is affirmed, as these comments were not deemed prejudicial enough to warrant such drastic measures.

Judgment Taxing Costs

Application: The trial court's decision to tax costs against the appellant was upheld, except regarding the prescription drug bills.

Reasoning: The judgment in favor of Webb is affirmed, except for the prescription drug bills, and the judgment taxing costs against the appellant is also affirmed.

Prohibition Against New Theories of Damages

Application: The introduction of evidence suggesting new theories of damages without prior disclosure is prohibited, aligning with established precedent.

Reasoning: This aligns with precedent that prohibits the introduction of undisclosed evidence that suggests new theories of damages.

Remittitur for Undisclosed Evidence

Application: The case was remanded for the trial court to adjust the judgment through a remittitur to account for the error in admitting the prescription drug bills.

Reasoning: As a result, the case is remanded for the trial court to grant a remittitur for the amount related to the prescription drug bills.