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NEIMAN NIX, etc. v. THE OFFICE OF THE COMMISSIONER OF BASEBALL, etc.

Citation: Not availableDocket: 21-0928

Court: District Court of Appeal of Florida; August 24, 2022; Florida; State Appellate Court

Original Court Document: View Document

Narrative Opinion Summary

In the appellate case of Neiman Nix and DNA Sports Performance Lab, Inc. versus The Office of the Commissioner of Baseball and others, the Third District Court of Appeal of Florida reversed a trial court order that granted the Appellees' motion for judgment on the pleadings. The Appellees contended that the Appellant's complaint was time-barred by the statute of limitations, citing previous complaints filed in 2014 and 2016 as evidence of the Appellant's knowledge of the cause of action. However, the appellate court found that, under Florida procedural rules, the Appellant's failure to respond to the Answer meant that the allegations concerning prior complaints were deemed denied. The court emphasized that for a motion for judgment on the pleadings, all well-pled allegations must be accepted as true, and any denied allegations cannot be used to support the motion. Consequently, the appellate court reversed the lower court's decision and remanded the case for further proceedings, as the prior complaints could not be authenticated as part of the pleadings for the purpose of summary judgment.

Legal Issues Addressed

Acceptance of Well-Pled Allegations

Application: The court reiterated that all well-pled material allegations of the opposing party must be accepted as true and allegations that have been denied cannot support a motion for judgment on the pleadings.

Reasoning: The court noted that all well-pled material allegations of the opposing party must be accepted as true when considering a motion for judgment on the pleadings, and any allegations that have been denied cannot be used to support such a motion.

Judgment on the Pleadings

Application: The appellate court held that a judgment on the pleadings is only appropriate when the moving party is entitled to judgment as a matter of law based solely on the pleadings.

Reasoning: The court emphasized that a judgment on the pleadings is appropriate only when the moving party is entitled to judgment as a matter of law based solely on the pleadings.

Procedural Denial of Allegations

Application: The court found that the allegations regarding prior complaints were considered denied due to procedural rules, thus invalidating their use as a basis for the judgment on the pleadings.

Reasoning: However, since the Appellant was not required to respond to the Answer, the allegations regarding these prior complaints were deemed denied, according to Florida procedural rules.

Statute of Limitations Defense

Application: The court determined that the Appellees' reliance on the statute of limitations defense was insufficient due to the procedural rule that the Appellant was not required to respond to the Answer, thereby denying the allegations.

Reasoning: The Appellees argued that the Appellants' Complaint was barred by the statute of limitations, asserting that the Appellant had knowledge of the potential cause of action more than four years prior to filing.