Following Trends in Florida Law

Archive for February, 2009

US Supreme Court 2009: Park Monuments and the “Recently Minted” Government Speech Doctrine

Thursday, February 26th, 2009

Since the Court agreed that certain Ten Commandment statues were permissable in municipal parks, it was only a matter of time for that First Amendment issue to be tested.  Oddly enough, the Court choose to testfire a rather new legal theory: government speech doctrine.

In Pleasant Grove City, Utah et al. v. Summum, a small municipality has a park with eleven privately-donated monuments, including a 10-Commandments monument.  A religious group, which isn’t even based in that city, wanted to donate its own monument with the “Seven Aphorisms of Summum.”  

To the  uninitiated, this Summum group believes Moses first got seven aphorisms from God but they were not understood; Moses went back to the Mount and returned with the more-easily understood Ten Commandments.  

The City declined the offer, claiming the proposed monument did not relate to the history of Pleasant Grove nor was it donated by a group with longstanding ties to the community.  Can the City do that, effectively choosing one religious speech over another?

Quick First Amendment primer: If the government engages in its own expressive conduct, there is no Free Speech application; that clause restricts government regulation but does not regulate the government’s own speech.  The government, however, is restricted by the Establishment Clause and is accountable to the voters.

The Court noted that permanent monuments on public property typically represents government speech, regardless whether the monument is state sponsored or privately donated.  Historically, government has exercised selectivity in picking and choosing its “monumental” speech.  

This is the basis for the government speech doctrine, which protects government when it selectively picks and  chooses it monuments.  It was acknowledged that parks likely can only accomodate a limited number of permanent monuments.  The message need not be singular and, instead, could change over time or even be ironic.  It is intrinsic that the government NOT be viewpoint neutral else it would have to brace itself for an influx of clutter from multiple, meaningless monuments.  Again, the government must still abide by the Establishment Clause and the ire of the voters.

While the majority opinion spins its wheels for is 11 pages, it is Justice Scalia and Thomas who cut to the nub of the case.  The City was a bit fearful of associating itself too much with the Ten Commandments, lest it trigger an Establishment Clause challenge.  Summum, sensing that, exploited that hesistation and argued that its proposed monument was not “government speech” since Pleasant Grove had not embraced the messgage of the competing monument.  Thus, Summum claimed that the City could not take advantage of the government speech doctrine since the City had distanced itself somewhat from the Ten Commandments monument.  Scalia and Thomas offered in dicta to avoid the issue coming back before the court that there would not be an Establishment Clause violation under these facts.

The Court is clearly uneasy with the (new) government speech doctrine, hence one majority opinion with FOUR concurrences.  In fact, the Justices stopped short of saying that the doctrine was outcome oriented.  It may take years but it will be interested to see this doctrine tested by more complicated fact patterns.

QUESTION: on the sidewalk along U.S. One, outside of the Lake Worth City Hall, is a short brick wall with the names of local houses of worship.  Is that protected government speech or an Establishment Clause violation?

Is Walt Disney a Health Care Provider?

Thursday, February 26th, 2009

A six-year, finger-pointin’ lawyer has taken the case of a Walt Disney World annual passholder who claims she suffered breach of contract, false arrest, and intentional infliction of emotional distress against the Orlando theme park when she was denied (1) the use of a special “unload” area and (2) ejected from the park after trying to use the Tower of Terror dozens of times each Saturday… for medical reasons.

The Complaint alleges that the Plaintiff had been a WDW annual passholder for nearly four years with routine access to a special unload access area (for quick re-entry) until she was barred in late 2008. 

The Osceola clerk of the court website indicates the Mouse has yet to file an Answer.  But that’s never quite the news buzz like filing a lawsuit…

“Legal” Drugs on Internet (salvia divinorum) NOT Legal in Florida

Thursday, February 26th, 2009

There has always been an “underground” interest in unusual or obscure hallucenegenic drugs and plants which somehow escaped the watchful eye of the FDA or state legislatures and are thus “legal.” 

We picked up an interesting news story — from all places, PC World Magazine (March 2009) – about the availability of psychedelic drugs, plants, and supplements online.  Of course, if it exists, its on the internet.  The immediate outcry was the widespread availability of these drugs for teenagers with a paypal or credit card account.  What is more surprising is that Florida legislators are already one step ahead — the “new” drug is already banned in Florida.

Apparently the fad is salvia divinorum, apparently some distant cousin of mint (hence the moniker, “magic mint”).  According to the Salvia Divinorum User’s Guide, this “visionary herb” can be smoked or chewed with auditory and behavioral changes lasting anywhere from 15 minutes to an hour.

Many sites exist which sell this plant, including Bouncing Bear Botanicals, Herbal Fire, andShaman’s Garden.  Most of these sites have warnings about consumption levels and when/where to take the drug; that said, the varieties and quantities sold (from about $9 - $25) appear confusing.  Potentcy was also unclear.  One site, NeuroSoup, gave vague and inaccurate information about the drugs legal status.  Thus, these sites are not giving clear technical information nor are they always giving accurate legal information.

 As mentioned above, Florida law seems on top of the issue despite the fact that the plant does not appear to be indigenous to the state.  Florida State 893.03(1)(c)(35) says salvia is a schedule I drug with a high potential for abuse and no accepted medical use (which seems strange since, for salvia, the statute prohibits Salvia divinorum, except for any drug product approved by the United States Food and Drug Administration which contains Salvia divinorum”).

Florida House Bill HB 495 May Change Slip-And-Fall Law?

Thursday, February 26th, 2009

Florida Representative Dave Murzin (R) of Pensacola recently introduced House Bill 495 which would change how slip and fall cases are tried in Florida.  The bill which could use some editing by a lawyer would repeal Florida Statute 768.0710 (Burden of proof in claims of negligence involving transitory foreign substances) and replace it with Florida Statute 768.0755.

So what’s the difference?  The current standard calls for the owner of a “business premises” to provide reasonable care of the premises, including reasonable care to ensure it is free from those ghastly transitory foreign substances which could give rise to loss, injury or damage.  The claimant must prove the defendant had ownership/control of the premises and their was negligence in the control, maintenance or operation of the premises.  To this end, actual or constructive notice (i.e., “you knew or should have known it was there”) is not a “required element” but can be considered.

For what it is worth, the battle over the significance of actual or constructive notice has been won and lost more than once in the past decade.  See Owens v. Publix.

Rep. Murzin proposes that the person who “slips and falls” on a substance at a “business establishment” (note that s. 768.0710 talks about “business premises”) must prove actual or constructive notice AND that the business “should have taken action to remedy it.”  A claimant could prove constructive notice (should have known it was there) by proving the length of time the substance was there or that it was regularly present and therefore foreseeable.

Of note, if the Bill becomes law as is, it is unclear if it applies to someone who trips and falls, since it says slips and falls.  Critics will likely claim that this shifts the burden to the plaintiff to (1) know or find out what the business owner did not know and (2) prove what they fell on and how long it was there which, if they had known those two pieces of information at the time, there would not be an injury.

We’ll see.  We note that Rep. Murzin also introduced a pro-nursing home, anti-long term care litigation bill as well: HB 493.  We will watch both…

Special thanks to MillerLaw on Twitter for the interesting catch.

Admissibility of Co-Defendant’s Settlement: Did the Florida Supreme Court Overrule Ehrhardt’s “Florida Evidence”?

Thursday, February 26th, 2009


Many Florida lawyers, particularly those with Florida school law degrees, clutch to their Ehrhardt “Florida Evidence” text.  And with good reason.  However that grasp should be loosened just enough to take a red pen to section 408.1 of the book.  You may also want to mark up your Florida Statutes 768.041(3) (release or covenant not to sue) and section 90.408 (compromise and offers to compromise).  Because the Florida Supremes ruled that evidence of settlement or dismissal of a former defendant is never admissible, even to challenge bias or credibility.

In Albert Saleeby v. Rocky Elson Construction, the Court tangled with a direct and express conflict between the Third and Fourth DCA on the issue of admissibility of a prior defendants settlement under these two statutes (Fourth District had permitted while the Third had not).  In the Saleeby facts, a defendant had been released from the case and later appeared in trial as an expert, opining a co-defendant had violated building codes.

The High Court cited the 4th District case and its citation to Ehrhardt’s text.  A dissent did as well.  But the opinion was that the plain meaning of both statutes prohibited admission for any reason.  The Court buttressed its opinion with a claim that admitting such evidence was contrary to a strong state public policy in favor of settlement.

A brief discussion was made about “Mary Carter Agreements,” a chimera of a legal theory which gets discussed more frequently than it is actually spotted in the wild.  A Mary Carter agreement, which was forbidden as of a 1993 opinion, involves a secret settlement between plaintiff and defendant where the defendant agrees to remain in the case and try to amplify a co-defendant’s liability.  The Court used words like “charade” and phrases like “unfair and unethical” and “outlawed their use” in describing such agreements.

Canady’s dissent was interesting as it argued that section 90.608(2)(attacking credibility by showing bias) was not subjacent to 768.041(3)(release or covenant not to sue) or 90.408.  He argued that, in this case, the plaintiff created its own situation by hiring the former defendant as an expert and placing him on the stand.  Justice Polston, meanwhile, plainly draw the conflict with Professor Ehrhardt by quoting the book upfront and then opining that the evidence should have been admissible since it was not admitted to prove liability but simply to show bias.

Ybor City Batman Arrested Under Anti-Ku Klux Klan “Mask” Law

Thursday, February 26th, 2009

Who knew Tampa had a crime-fighting version of the Naked Cowboy?  Apparently Walsh Nichols, a Tampa-area college student, began dressing as Batman and frequenting Ybor City… complete with a black motor scooter with the batman emblem.  One night in October, police arrested Nichols under Florida Statute 876.12 for wearing a mask in public (a charge, we note, under a “criminal anarchy” statute).  According to Nichols, he was wearing the suit but was simply eating sushi at the time; however, he had been warned to take off the mask earlier in the evening. 

Tampa Bay Online broke the story – which we agree had to be reported —  yet succumbed to the urge to use every Batman cliche.  We’ll tastefully avoid that here and even regret that initial reference to the Naked Cowboy above.  Of course the legal issues got lost in the pow-zap-bam silliness.  Also lost in the story was the citation that Batman apparently did not have the license endorsement to ride the bike.

Does the story end there?  Not when local Tampa news can get video for a human interest segment which they entitle, “Batman Seeks Justice.”  

Indeed Batman, er, Nichols hired attorney Kevin Hayslett of Carlson & Meissner who filed a Motion to Dismiss and Motion to Suppress, pointing out that the 1951 no-mask-in-public law has a 1981 companion, Florida Statute 876.155, which requires that the masked-person have certain criminal “intent” before it is a crime.  The Motion cites a 1980 Florida Supreme Court case which held that the old anti-Ku Klux Klan law could be overbroad; that case apparently inspired the 1981 statute.  

As a seedling which could give rise to an appeal to the U.S. Supreme Court, the Motion also cites the Fourth Amendment prohibition against unlawful search and seizure (a federal law involving a U.S. Constitutional right, hence the potential road to the High Court).  The defense claims the police had no basis for the arrest since the sushi-eating Batman exhibited no criminal intent. 

Nichols primed the news with some campy comments, such as the fact that he and his friend do not go to Ybor anymore since they can’t wear their masks.  His friend who dresses like Robin, of course.  Both dutifully have their own Myspace pages, so you can see Batman and Ybor Robin.  A (soon-to-be well circulated) Myspace page has an arrest photo with Batman in full attire.

Second DCA Judge Accused of “Fiscal Shenanigans” (but not sex) With Stripper

Thursday, February 26th, 2009

The Tampa-area papers have quietly but persistently been following the story of Judge Thomas E. Stringer, Sr. of the Second District Court of Appeal who is in hot water with the Florida Judicial Qualifications Committee for hiding assets and other alleged mis-deeds with an aging stripper.  For those who need the salacious details with pictures of our judge and exotic dancer, see this St. Pete Times article.  

Apparently Hizzoner and our lady of the night met at a diner in Tampa and that turned into a relationship involving Hawaiian property, exotic cars as gifts, bankruptcies in Vegas, and Rolex gifts (we note that Ms. Yamanaka graciously gave one of the watches to Mrs. Stringer).  

Read the JQC’s Notice of Formal Charges.  Note the first paragraph (of course) has to point out that Yamanaka is an “exotic dancer” but then there is no mention of any sexual impropriety in the Notice.  The media dutifully took the bait.  The story has received national coverage because of the stripper-angle: note how the USA Today’s title, “Judge Accused of Sheningans With Stripper”  is a misleading  cheeky re-packaging of the local paper’s title, “JQC Accuses Judge of Fiscal Shenanigans.”  The omission of the word “fiscal” in the title makes a key difference, doesn’t it?

U.S. Supreme Court: Police Can Mistakenly Arrest Someone and Still Convict on Evidence Obtained

Thursday, February 26th, 2009

The United States Supreme Court affirmed an Eleventh Circuit Court opinion today finding that police negligence which lead to the arrest of a person without probable cause or a valid warrant was not grounds to exclude the discovered gun and drugs.  In short, a person with a prior record who was mistakenly arrested will face felony charges based upon what he was carrying when wrongly arrested.

The Fourth Amendment to the Constitution protects people from unreasonable searches and seizures.  The Constitution does not provide any protection against the use of the improper search/seizure.  A judicially-created “exclusionary” rule, however, does exist — favoring both criminals and tv crime show writers.

In this case, an astute investigator learned that a known criminal was coming to the police station and asked the clerk to check if there were any warrants out for the known criminal’s arrest.  None were found in the county but the clerked called the neighboring county, which reported there was a felony warrant.  The defendant was arrested on that information.  Within minutes, it was established that the other county had a clerical error and there was no warrant.  But the police had already found a gun (our known criminal was a felon) and meth.  Criminal defense counsel sought to suppress/exclude the evidence since it was improperly obtained.

The High Court played a bit of a cat and mouse game as to whether there was a 4th Amendment violation; nonetheless, since the parties had agreed there was a violation, the question was whether the exclusionary rule applied.  If you watch a lot of tv, you would think it was automatically excluded.

Yanking us back to reality, Chief Justice Roberts wrote in  Bennie Dean Herring v. United States that the exclusionary rule “has been our last resort, not our first impulse.”  It is not an individual right and, instead, only applies when it results in some appreciable detterence of constitutional violations by the police.  The Court used the “objectively reasonable” standard (a good faith/knew or should have known approach) in evaluating the conduct here — which, admittedly, does seem free of any intentional misdoing by the police.

The dissent complained that there was not a sufficient rule in place to determine where/when exclusion would apply.

I’m not a criminal lawyer but the facts of this particular case seem extreme in terms of showing this was “simple negligence” in otherwise good faith law enforcement.  That said, this was a 5-4 decision.  As such, while the wording of the Opinion is quite strong, one might guess that muddier facts in future cases may yield the opposite outcome.

Non-Florida Lawyer (Who Advertises in Florida) Spent $20 Million on Ads

Thursday, February 26th, 2009

According to this ABA Journal article, Massachussets lawyer, James Sokolove, is the biggest spender on legal advertising in the country — including Florida, where his print ads intentionally only use basic block lettering.  He spent $20 million on advertising in 2007 alone.  In this Boston Magazine article that he prefers to spend downwards of $1,500 per tv ad rather than produce a higher quality ad — finding them both equally as effective.  

Despite his national advertising presence, including places like I-95 and the Florida Turnpike, Sokolove reportedly “no longer tries any cases” and, historically, “he’s argued only one case before a jury; it was back in the 1970’s and he lost.”  The articles cited above indicate that his firm is “keeping tabs on some 10,000 referred cases…” 

The Massachusetts Law Weekly Blog “The Docket” reported that Sokolove’s firm is for sale  despite the fact that “the assets would include virtually no attorneys as Sokolove refers the many calls his ads generate to a network of hundreds of other lawyers.”  

A member search on the Florida Bar website did not reveal Mr. Sokolove is a Florida lawyer.   The Law Offices of James Sokolove, LLC is a Florida business entity but no Florida address is given.  A search on Sokolove’s website did not reveal a Florida office.

The Defense Lawyer Who Became a Plaintiff Lawyer

Thursday, February 26th, 2009

At the end of December, the Florida Supreme Court quietly laid to rest a nearly four year old squirmish between a defense-attorney-turned-plaintiff-attorney and his former nursing home client.  In doing so, after two trips to the Fourth DCA and one trip to the Supremes, we have an interesting swath of case law which clarifies the rules for lawyers moving firms, particularly from a defense firm to a plaintiff firm. 

The facts of the underlying case in  Peggy Bradley as Personal Representative of the Estate of Buford Allen Fennell v. Health Care & Retirement Corp. of America reveal a fairly standard nursing home lawsuit (ulcers and falls) arising from a January 2002 - September 2005 admission period.  Meanwhile, a West Palm Beach insurance defense lawyer worked for the defendant on similar cases at various times from February 2001 - December 2004.  It was introduced that the lawyer worked 2,100 hours for the former client in over 60 cases.  In January 2005, he switched law firms and became Plaintiff’s counsel.  The defendant moved to disqualify the lawyer and the Palm Beach Circuit Court denied the motion.

In Health Care v. Bradley I (December 2006),  the Fourth DCA, in a per curiam rehearing, held that the inquiry was whether Rules Regulating the Florida Bar 4-1.9 and 4-1.10 had been violated, specifically whether the pending matter was the “same or a substantially related matter” in comparison to the lawyer’s prior cases wherein he represented the defendant.  The Court noted there was an irrebutable presumption that confidences are disclosed in the course of the attorney-client relationship but disqualification of counsel was not required merely because of that irrefutable presumption.    

Upon remand, without further evidence, the trial court again denied the motion. 

In Health Care v. Bradley II (July 2007), the Fourth DCA (Gross, Shahood and Pollen) focused on the “substantially related” test and determined that the instant matter was not the “same” matter as counsel had previously defended.  Moreover, the case at bar was not “substantially related” to counsel’s prior defense work.  Despite the number of cases and hours worked for the former client, the Court felt that the prior cases did not involve the same transaction nor did the lawyer have to attack his prior work.  More succinctly, the Court found the lawyer had handled a “type of problem” for the defendant and then represented an adverse party in a “wholly distinct problem of that type.”  With that, the appellate court held that there was no error in denying the motion to disqualify.

The defendant appealed to the Florida Supreme Court, claiming a conflict with another intermediate district court opinion.  

In Health Care v. Bradley III, the Florida Supreme Court acknowledged that it had taken jurisdiction but then decided that it did not care that “jurisdiction was improvidently granted.”  Note: this is not the only case where the Florida Supreme Court changed its mind regarding jurisdiction on the eve of 2008.

Thus, the standard for disqualification under Rule 4-1.9 is a test of whether an attorney’s representation of a party adverse to a former client is the “same or substantially related” to counsel’s prior work for the former client, with little importance placed on the number of cases or hours previously worked.  Indeed, the “irrebutable presumption” standard suggests that it makes little difference if the lawyer had previously worked 100 or 1,000 hours for his former client — the narrow question of disqualification is whether the now-adverse-lawyer is working on the same or substantially related matter.

Liability Waivers Signed by Parents for Children to Participate in Commercial Activity are NOT Enforceable

Thursday, February 26th, 2009

The Florida Supreme Court took up the question of the enforceability of (fairly common) “pre-injury” liability waivers/general releases which are signed by parents so their children can participate in commercial activities. Finding this an issue of “great public importance,” the Court held that these releases are NOT valid. If, however, the waiver is for the child to participate in non-commercial activities such as school or community events, such a waiver could be valid.

As the dissent points out, it is odd for the Florida Supreme Court to enunciate a public policy (of great public importance) despite no such prior reference in Florida general or statutory law. Moreover, quickly Florida lawyers will question (a) whether the parents can be called upon to indemnify the activity operator or (b) whether a case involves a commercial or school/community activity.

The case of Scott Corey Kirton et al. v. Jordan Fields et al.; Dean Dyess v. Jordan Fields; and H. Spencer Kirton v. Fields were consolidated appeals arising from an August 2007 Fourth District Court of Appeal decision.

Our prior post gives the backdrop of case law which lead to this Florida Supreme Court ruling, which should not have come as a shock in light of the hints dropped in the 2005 Global Travel v. Shea opinion.

The Court held that “a parent does not have the authority to execute a pre-injury release on behalf of a minor child when the release involves participation in commercial activity.” In a quick footnote, the Court then qualified that this decision would only be dicta if (when!) the questions arise about the enforceability of parent-signed exculpatory agreements for children to participate in non-commercial activity.

That creaking noise you hear is the door being swung wide open for appeals arising from the enforcement of liability waivers in non-commercial cases as well as in instances where it is unclear whether an activity is commercial or non-commercial.

The Court admitted there is no statute on point. It did, however, find that this situation invoked the State’s parens patriae public policy basis to preclude the enforcement of such waivers. Signing a pre-injury waiver was deemed not to be so much a part of a fundamental right of raising children but more an “injustice” which “deprives the child of the right to legal relief” and could lead the child, family, and the State to “suffer.” Signing the waiver “impacts the minor’s estate and the property rights personal to the minor.”

A short-shifted discussion was then had about how commercial activities could afford insurance and/or pass the cost along to the consumer; hence the differential treatment.

Justice Wells concurred but noted that “until today, this Court has never held that such a pre-injury release knowingly executed by a parent is unenforceable.” He further pointed out, given the number of cases on point, that the Legislature certainly had the opportunity to outlaw such provisions — and didn’t. He concluded, “it is fundamentally unfair to now declare a new public policy and then apply it to the defendants in this case.”

While Florida parents will likely collectively sigh with relief, this new public policy which divides commercial and non-commercial activity into two poorly-defined camps may lead to confusion — if not mistaken decisions — involving signing releases in quasi-commercial (or questionably non-commercial) activities.

iPhone Apps for Lawyers, Part I

Thursday, February 26th, 2009

As mentioned before, the iPhone has been an impressive phenomenon to watch, both from a legal sense (e.g., is the AT&T terms of service contract unconscionable?) and from a tech perspective (e.g., is this a tethered device or a generative one?).  The leap from a novel cell phone to a resource of new “Apps” has made it even more essential.

The only truly law-related App seems to be the free e-copy of the Constitution.  OK, but probably not something for your main screen.

The ABA Journal puts news pieces (but not deep legal articles) in its own aggregating App, which is probably the only real meaningful lawyer App in the bunch.

Trial lawyers may want to pay attention to the USA Today, not necessarily because of the news but because of the national, state and local public poll results.  Consider it the iPhone version of the little graphics in the bottom corner of the USA Today paper.  But, for lawyers holed up in their office and/or surrounded by other lawyers all day long, it is a good way to keep track of what “normal” people do or think — consider it prep work so you can be a little more “with it” when selecting a jury.

Other Apps on the iPhone right now: Mobile News, News USA, Newsdesk, Scoop Free, Twittelator, LinkedIn, Facebook, SnapTell, Weather Channel, Flixster, Amazon.com, BookSearch, OpenTable, DopplerLite, vlingo, and Google Earth.

So what’s in your iPhone?

Move from FloridaArbitrationLaw.com

Thursday, February 26th, 2009

Welcome to Florida Law Commentary, a website devoted to trends in Florida law, specifically focused on new decisions issued by Florida courts. 

This project began several years ago with Florida Arbitration Law.com, which had an intentionally narrow scope.  Ironically, the common mistake of bloggers is to take on too much of a topic; arbitration was great, and certainly enough for a blog, but the challenge of keeping up a blog was met and overcome.  In fact, we’ll continue to keep that blog going.

Over the years, even with plenty of material, the desire to discuss other developments outside of arbitration/mediation could not be ignored.  The temptation to address other topics grew simply too great. 

This (new) site provides an unrestricted platform which hopefully will not be too overwhelming. The primary goal of the site is to report and comment on critically important decisions as they come out — before it hits the paper copy of Florida Law Weekly — and before that hot new case makes the rounds in the courthouse.  The final intent is to report on trials, new concepts, legal news, and practice theories.  Maybe even rumor.  Who knows.  

The intended readers are likely Florida lawyers, if not specifically Palm Beach lawyers, and others interested in civil litigation developments in this state.  An emphasis on contracts, construction, health care, negligence, nursing home/ALF, probate, and wrongful death law should become apparent. 

This site is pure opinion, not always serious, and none of this is intended as legal advice.  It’s not an advertisement.  You know not to believe everything you read on the internet.  Also, there’s no sharing of blame: nothing here should be construed as the opinions of any law firm, client, business entity or anyone else other than the author.  In fact, whatever is written here may simply be a passing notion.

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