Deauville Hotel Management, LLC, Etc. v. Ward, 219 So. 3d 949

Kemesia Ward contracted with Deauville Hotel to hold her July 9, 2010 wedding reception; the contract referenced “function space” and stated the hotel would assign/reserve function space and, if unable to provide requested space, would arrange comparable alternative space.
The hotel’s records (computer reservation, banquet event order, emails/texts) identified the Richelieu ballroom as the reserved space for the reception.
Nine days before the wedding the city red-tagged the hotel’s ballrooms as unsafe; the hotel did not notify the Wards and unsuccessfully sought relief from the city; the ballroom remained closed on the wedding day.
The hotel moved the reception to a cramped lobby area (Napoleon Pre-function area) that lacked privacy, space for guests/bridesmaids, ocean view, and separation from hotel guests; the event was disrupted and caused Ward emotional distress.
The Wards sued for breach of contract (Ward), third-party beneficiary breach (husband), and intentional infliction of emotional distress (IIED); a jury awarded $23,000 to Ward and $2,500 to husband for breach, and $5,000 for IIED.
The appellate court affirmed breach liability but reversed excess damages above the $12,985.65 food-and-beverage contract amount, awarded nominal damages ($1) to husband, and reversed the IIED verdict.

Issue	Plaintiff's Argument	Defendant's Argument	Held
Did the hotel breach the contract by moving the reception from the Richelieu ballroom to the lobby?	Ward: Richelieu was the assigned/committed function space; lobby was not a comparable alternative.	Deauville: contract allowed reassignment of “function space”; no specific promise of Richelieu.	Held for Ward: contract reserved assigned function space (Richelieu); the lobby was not a comparable substitute.
Were the jury’s breach-of-contract damages supported by the evidence?	Ward: damages include $9,500 in incidental expenses plus $15,000 rental value of Richelieu, supporting $25,500 award.	Deauville: plaintiffs paid $12,985.65 for food/beverage (which included room); award exceeded actual loss and created a double recovery.	Held for Deauville in part: affirm damages for $12,985.65 (food/beverage); reversed awards above that amount and precluded recovery for room rental and duplicate incidental expenses.
Did the hotel’s conduct constitute IIED (extreme/outrageous conduct)?	Ward: the hotel’s bait-and-switch and public humiliation on her wedding day were intentional and caused severe emotional harm.	Deauville: conduct was bad and tortious but not outrageous as a matter of law; not comparable to life-or-death or reputation-ruining conduct in IIED precedents.	Held for Deauville: conduct did not meet the legal threshold of outrageousness; IIED verdict reversed.

R.J. Reynolds Tobacco Co. v. Ballard, 163 So. 3d 541 (Fla. 3d DCA 2015) (standard for appellate review of directed verdict denial)
Meruelo v. Mark Andrew of Palm Beaches, Ltd., 12 So. 3d 247 (Fla. 4th DCA 2009) (any reasonable view of the evidence sustaining verdict defeats directed verdict)
Murciano v. Garcia, 958 So. 2d 423 (Fla. 3d DCA 2007) (elements of breach of contract)
MCI Worldcom Network Servs., Inc. v. Mastec, Inc., 995 So. 2d 221 (Fla. 2008) (compensatory damages principles; no windfalls or double recovery)
Kingswharf, Ltd. v. Kranz, 545 So. 2d 276 (Fla. 3d DCA 1989) (prohibition on double recovery for same damages)
LeGrande v. Emmanuel, 889 So. 2d 991 (Fla. 3d DCA 2004) (IIED standards; examples of insufficiently outrageous conduct)
De La Campa v. Grifols Am., Inc., 819 So. 2d 940 (Fla. 3d DCA 2002) (court as matter of law determines whether conduct is outrageous)
Clemente v. Horne, 707 So. 2d 865 (Fla. 3d DCA 1998) (definition of outrageous conduct for IIED)
Food Lion, Inc. v. Clifford, 629 So. 2d 201 (Fla. 5th DCA 1993) (false accusation insufficient for IIED)
Williams v. Worldwide Flight SVCS., Inc., 877 So. 2d 869 (Fla. 3d DCA 2004) (racial epithets and firing threats insufficient for IIED in that context)
Liberty Mut. Ins. Co. v. Steadman, 968 So. 2d 592 (Fla. 2d DCA 2007) (insurance denial to hasten death constituted outrageous conduct)
Thomas v. Hospital Bd. of Dirs. of Lee Cnty., 41 So. 3d 246 (Fla. 2d DCA 2010) (cover-up of negligent death can support IIED)