Board of Trustees v. American Educational Enterprises, LLC
99 So. 3d 450
| Fla. | 2012Background
- Board of Trustees of the Internal Improvement Trust Fund is the state entity dispositioning state lands.
- American Educational Enterprises (American) is assignee of Florida National College’s contract for sale of state property.
- Property was purchased in 2001 for $3.75M; bid package disclosed “as is,” with a minimum price and various disclosures.
- Citibank appraisal valued property at $2.85M; 1999 appraisal valued it at $3.275M and was not in the bidding package.
- American assigned rights to American; discovery dispute arose over confidential financial documents produced under a confidentiality agreement.
- Trial court ordered production of documents; Third District granted certiorari, quashing the order as overbroad; Florida Supreme Court quashes and reinspects certiorari standards.
- Court rejects reliance on overbreadth as basis for certiorari relief and holds discovery of relevant financial information is permissible; order found not to cause irreparable harm; certiorari relief denied on these grounds.
Issues
| Issue | Plaintiff's Argument | Defendant's Argument | Held |
|---|---|---|---|
| Whether Third District used correct certiorari standard | American relied on irreparable-harm standard | Board argues overbreadth alone suffices | Third District erred; irreparable-harm standard applies |
| Whether discovery of financial documents was proper | Disclosures relate to American’s bid value | Disclosures aid defense and damages proof | Discovery of relevant financials permissible; no irreparable harm |
| Whether overbreadth alone supports certiorari relief | Overbreadth justified certiorari relief | Overbreadth not alone a certiorari basis | Overbreadth is not a proper basis for certiorari relief |
Key Cases Cited
- Martin-Johnson, Inc. v. Savage, 509 So.2d 1097 (Fla. 1987) (limits certiorari review; irreparable harm requirement)
- Allstate Ins. Co. v. Langston, 655 So.2d 91 (Fla. 1995) (irrelevant discovery not automatically irreparable harm)
- Reeves v. Fleetwood Homes of Fla., Inc., 889 So.2d 812 (Fla. 2004) (certiorari limits; non-final orders reviewed sparingly)
- Brooks v. Owens, 97 So.2d 693 (Fla. 1957) (limits on certiorari review for non-final orders)
- Jaye v. Royal Saxon, Inc., 720 So.2d 214 (Fla. 1998) (framework for limited certiorari jurisdiction)
- Allstate Insurance Co. v. Boecher, 733 So.2d 941 (Fla. 1999) (confirms strict limits on certiorari review)