Publix Supermarkets, Inc. v. Santos, 118 So. 3d 317

Plaintiff Marisol Santos sued Publix for negligence after slipping on a transitory substance near an in-store kiosk on May 25, 2011 at a specific Publix store in Miami.
Santos requested discovery of all slips and falls at that specific store for the three years before her accident; Publix responded that there were no prior incidents at that store.
Santos later sought broader discovery: depositions and incident reports for occurrences at kiosks in all Publix stores in Florida.
Publix objected and moved for a protective order, arguing Florida’s slip-and-fall statute, section 768.0755, limits discovery to the particular business establishment where the accident occurred.
The trial court ordered Publix to supplement its interrogatory responses with statewide incident reports; Publix petitioned this Court for a writ of certiorari to quash that discovery order.

Issue	Plaintiff's Argument	Defendant's Argument	Held
Scope of discovery under §768.0755: whether discovery may extend to incidents at other stores statewide	Santos sought statewide kiosk incident reports to show pattern or notice	Publix argued §768.0755 confines inquiry to the specific "business establishment" where the slip occurred; statewide data is irrelevant and unduly burdensome	Court held §768.0755 refers to the particular business establishment; statewide incident reports are irrelevant and the order granting them was quashed
Availability of certiorari review for discovery order	Implicit: broad discovery justified for notice	Publix: order departs from essential requirements of law and causes irreparable harm with no adequate appellate remedy	Court granted certiorari, finding the discovery order granted "carte blanche" to irrelevant discovery and thus departed from the essential requirements of law

Allstate Ins. Co. v. Langston, 655 So.2d 91 (Fla. 1995) (standards for certiorari review of discovery orders)
Board of Trs. of Internal Improvement Trust Fund v. American Educ. Enters., LLC, 99 So.3d 450 (Fla. 2012) (certiorari appropriate when discovery grants "carte blanche" to irrelevant materials)
West Fla. Reg. Med. Ctr., Inc. v. See, 79 So.3d 1 (Fla. 2012) (de novo review of statutory interpretation)
Capella v. City of Gainesville, 377 So.2d 658 (Fla. 1979) (omission of language in amended statute implies changed meaning)
Carlile v. Game & Fresh Water Fish Comm’n, 354 So.2d 362 (Fla. 1977) (legislative language changes indicate intent to alter meaning)
United Auto. Ins. Co. v. Salgado, 22 So.3d 594 (Fla. 3d DCA 2009) (use dictionary/plain meaning to define undefined statutory terms)
Gardner v. Johnson, 451 So.2d 477 (Fla. 1984) (statutory terms can be given plain and ordinary meaning via dictionaries)