The case involved a wrongful death lawsuit filed by the estate of a passenger killed in an airplane crash against Aerolease, the owner-lessor of the aircraft. The plaintiff sought to hold Aerolease vicariously liable under Florida's dangerous instrumentality doctrine for the pilot's alleged negligence, as well as for Aerolease's own negligent maintenance and inspection. The trial court granted summary judgment to Aerolease, finding that federal statute 49 U.S.C. § 44112 preempted the state-law vicarious liability claim. The Florida Supreme Court held that the federal statute does not preempt Florida law because its liability limitation applies only to injuries occurring 'on land or water,' not to deaths occurring in flight, and therefore the vicarious liability claim could proceed.
This case arose from Lazaro Sosa's lawsuit against Safeway Premium Finance Company claiming that Safeway violated Florida statutes by knowingly charging an additional $20 service fee twice within a twelve-month period under premium finance agreements for automobile insurance. The trial court granted Sosa's motion for class certification, but the Third District Court of Appeal reversed, concluding that commonality and predominance requirements under Florida Rule of Civil Procedure 1.220 were not met. The Florida Supreme Court quashed the Third District's decision, ruling that the appellate court applied the wrong standard of review by failing to defer to the trial court's factual findings and instead conducting a de novo review instead of reviewing for abuse of discretion. The Court further held that the Third District erred in its analysis of the statutory "knowingly" requirement and class certification criteria, approving decisions from other districts that properly addressed commonality and predominance when a common course of conduct was alleged.
The case G.M. v. State involved a juvenile approached by undercover officers in a park who activated emergency lights on their unmarked vehicle, approached a parked Lexus, detected marijuana odor, and recovered contraband after G.M. placed it in his mouth, resulting in a possession charge. G.M. moved to suppress the evidence, claiming the light activation effected an unconstitutional seizure without reasonable suspicion under the Fourth Amendment. The Florida Supreme Court held that activation of police lights is not dispositive but only one factor in the totality-of-the-circumstances test for whether a seizure occurred. The court reasoned that per se rules are disfavored in Fourth Amendment analysis and that the inquiry focuses on whether a reasonable person in the defendant's position would have felt free to leave.
This case involved a conflict among Florida district courts of appeal over the standards juvenile courts must follow when departing from the Department of Juvenile Justice's recommended restrictiveness level for committing a delinquent child to residential treatment. The Florida Supreme Court held that chapter 985, Florida Statutes, requires juvenile courts to justify any departure by providing reasons that compare the characteristics of the imposed restrictiveness level to the child's individual rehabilitative needs and treatment plan, supported by a preponderance of the evidence. The court reasoned that the statutory scheme, read as a whole, emphasizes both rehabilitation in the least restrictive setting and protection of the public, so departures cannot rely on information already considered by the DJJ or on generic factors. It therefore quashed the Fourth District's decision in E.A.R. and aligned with the standard applied by the First, Second, and Fifth Districts.
This advisory opinion addresses the validity of financial impact statements prepared for two proposed Florida constitutional amendments that would add standards for drawing state legislative and congressional districts, including requirements for equal population, compactness, use of existing boundaries, contiguity, and prohibitions on favoring political parties, incumbents, or diluting minority voting power. The court reviewed whether the identical statements, which estimated increased state costs in the "millions of dollars" from anticipated litigation without further detail, complied with statutory requirements for clarity and lack of ambiguity. The court determined that the statements were invalid because the vague reference to "millions of dollars" could mislead voters about potential costs, consistent with prior precedent condemning imprecise fiscal language on ballots. The reasoning centered on the need for financial impact statements to be clear and unambiguous under section 100.371, Florida Statutes, so that voters receive accurate information about revenue or cost effects.
This case is an advisory opinion requested by the Florida Attorney General on the validity of two initiative petitions proposing constitutional amendments to establish standards for legislative and congressional district boundaries. The Florida Supreme Court reviewed whether the proposals satisfy the single-subject requirement of the state constitution and whether their ballot titles and summaries comply with statutory requirements. The court concluded that the amendments meet these standards because they address interrelated redistricting criteria without engaging in logrolling or implicitly repealing other constitutional provisions, and the summaries accurately reflect the proposals' effects on party favoritism, minority voting rights, contiguity, compactness, and population equality. As a result, the court approved both amendments for placement on the ballot.
