Beltran v. Vincent P. Miraglia, M.D., P.A., 125 So. 3d 855

Miraglia sued Beltran individually in March 2009 for office overhead; alleged oral contracts, unjust enrichment, and quantum meruit.
Beltran affirmative defense: plaintiff failed to join Beltran’s professional association, M.D. P.A., as indispensable party.
Trial began November 2011; plaintiff amended to add Beltran’s P.A. during trial after testimony that agreements were with P.A.s.
Court allowed amendment, with defense to amend to raise statute-of-limitations defense for the P.A.
Trial court awarded $53,260 to Miraglia for goods/services June 2004–June 2006 on unjust enrichment/quantum meruit; defendants moved for involuntary dismissal against Beltran individually, citing lack of personal agreement.
Court reversed and remanded, holding no evidence supported personal liability of Beltran and that the P.A. claim was untimely; relation back did not save the P.A. claim.

Issue	Plaintiff's Argument	Defendant's Argument	Held
Personal liability of Beltran for damages	Miraglia argued Beltran personally entered into the agreement.	Beltran argued the agreement was with the P.A., not personally.	Not supported; no evidence of a personal agreement.
Statute of limitations for P.A. claims	P.A. claims relate back to 2009 filing.	Time-barred;4-year limit applies.	Barred; damages for 2004–2006 time period are untimely.
Relation back to add P.A. as party	Amendment relates back to original pleadings.	Addition of new party does not relate back; identity-of-interest not sufficient.	Relation back does not apply; P.A. claim is untimely.

Gasparini v. Pordomingo, 972 So.2d 1053 (Fla. 3d DCA 2008) (piercing corporate veil requires three factors; no evidence here.)
Seminole Boatyard, Inc. v. Christoph, 715 So.2d 987 (Fla. 4th DCA 1998) (veil-piercing standard cited.)
Cabot v. Clearwater Construction Co., 89 So.2d 662 (Fla.1956) (relation back as to misdescription vs. new party.)
Garrido v. Markus, Winter & Spitale Law Firm, 358 So.2d 577 (Fla.3d DCA 1978) (no relation-back where adding separate individuals; excusable neglect not shown.)
Graney v. Caduceus Props., LLC, 91 So.3d 220 (Fla.1st DCA 2012) (relation back limitations for party amendments.)
Frankowitz v. Propst, 489 So.2d 51 (Fla.4th DCA 1986) (treating physician not shown to have identity of interests with employer to relate back.)
Davis v. Monahan, 832 So.2d 708 (Fla.2002) (unjust enrichment accrues when benefit conferred.)
Swafford v. Schweitzer, 906 So.2d 1194 (Fla.4th DCA 2005) (statute of limitations for unjust enrichment/quantum meruit accrues on services/goods transfer.)
Matthews v. Matthews, 222 So.2d 282 (Fla.2d DCA 1969) (accrual in quantum meruit/valebant.)
3618 Lantana Rd. Partners, LLC v. Palm Beach Pain Mgmt., Inc., 57 So.3d 966 (Fla.4th DCA 2011) (de novo review of legal LIS; involuntary dismissal standard.)
Rayner v. Aircraft Spruce-Advantage, Inc., 38 So.3d 817 (Fla.5th DCA 2010) (identity-of-interest consideration for relation back.)