State Farm Mutual Automobile Insurance Company v. Statsick
2D15-5388
| Fla. Dist. Ct. App. | Jul 14, 2017Background
- Statsick (former Michigan resident) sued State Farm in Florida (2011) for PIP benefits from a Michigan accident; parties agreed to a stipulated judgment for $30,000 under a Michigan rule and the court entered judgment; State Farm paid.
- In 2014 Statsick filed a new Florida suit for additional PIP benefits for medical expenses incurred after the 2011 complaint.
- State Farm moved for summary judgment in 2014 arguing the 2011 stipulated judgment barred the later claims by res judicata; the trial court denied summary judgment and stated the parties had not reached a "meeting of the minds."
- Statsick then moved under Fla. R. Civ. P. 1.540(b) in the 2011 case to vacate the stipulated judgment, arguing the lack of meeting of minds made the settlement (and thus the judgment) void.
- The trial court granted relief and vacated the 2011 stipulated judgment; State Farm appealed.
Issues
| Issue | Plaintiff's Argument | Defendant's Argument | Held |
|---|---|---|---|
| Whether a judgment entered pursuant to a settlement that lacks a "meeting of the minds" is void under rule 1.540(b)(4) | Statsick: absence of meeting of minds renders the underlying agreement void and thus the judgment voidable as void under (b)(4). | State Farm: settlement defects do not render a judgment void; such judgments are voidable, not void, so (b)(4) inapplicable. | Court: Judgment is voidable, not void; (b)(4) relief was legal error. |
| Whether the trial court could vacate the judgment under other subsections of rule 1.540(b) (e.g., mistake (b)(1), fraud (b)(3)) based on the trial court's finding of no meeting of minds | Statsick: factual finding in 2014 order shows no meeting of minds and supports (b)(1)/(b)(3) relief. | State Farm: no evidentiary support in the 2011 case; summary-judgment record cannot supply findings for a separate 1.540(b) vacatur. | Court: No competent, substantial evidence was presented in the 2011 case to support vacatur under any 1.540(b) subsection; vacatur was an abuse of discretion. |
| Whether the summary-judgment order in the 2014 case could serve as evidentiary basis to vacate the 2011 judgment | Statsick: the 2014 order finding no meeting of minds supplies factual proof. | State Farm: summary-judgment proceeding record is limited; that finding is surplusage and not a full evidentiary determination for vacatur. | Court: 2014 summary-judgment finding is immaterial and cannot substitute for evidence in a 1.540(b) proceeding. |
| Whether disagreement about the preclusive effect of the stipulated judgment justifies vacatur | Statsick: parties’ differing beliefs about preclusive scope shows ambiguity in settlement. | State Farm: disagreement about preclusion is a preclusion-law question, not a contract defect that invalidates the judgment. | Court: Disagreement over preclusive effect does not warrant vacating a valid stipulated judgment under rule 1.540(b). |
Key Cases Cited
- Belk v. McKaveney, 903 So. 2d 337 (recognizes abuse-of-discretion review for 1.540(b) orders)
- Casteel v. Maddalena, 109 So. 3d 1252 (questions of law in 1.540 determinations reviewed de novo)
- Morley v. Dep’t of Health & Rehab. Servs., 570 So. 2d 402 (settlement agreement incorporated into judgment does not render the judgment void)
- Greenwich Ass’n, Inc. v. Greenwich Apartments, 979 So. 2d 1116 (judgment entered pursuant to a void settlement is voidable, not void)
- Sterling Factors Corp. v. U.S. Bank Nat’l Ass’n, 968 So. 2d 658 (voidable judgments are not subject to rule 1.540(b)(4) collateral attack as void)
- Sourcetrack, Inc. v. Ariba, Inc., 34 So. 3d 766 (trial court must have competent substantial evidence to exercise discretion under 1.540)
- PS Marinas 3 v. Marina Funding Grp., Inc., 889 So. 2d 167 (surrounding circumstances and evidentiary support required to determine parties’ intent/meeting of minds)
- Arrieta-Gimenez v. Arrieta-Negron, 551 So. 2d 1184 (consent judgments carry same preclusive effect as other judgments)
- Lunas v. Cooperativa de Seguros Multiples de Puerto Rico, 100 So. 3d 239 (contract formation measured by external expressions; mutual external agreement controls)