308 So.3d 961
Fla.2020Background
- Fatal rear-end collision; the decedent’s estate sued the lead (front) car driver and the driver’s employer.
- Trial court granted summary judgment for defendants based primarily on the front car’s forward-facing dash‑cam video, which appeared to contradict the Estate’s version of events.
- The Fifth District reversed, concluding the trial court improperly weighed competing evidence and stating Florida’s standard precludes summary judgment if the record raises even the "slightest doubt" about material facts.
- The Fifth District certified a question asking whether Florida should recognize an exception permitting final summary judgment when unaltered video evidence completely refutes the nonmoving party’s account.
- The Florida Supreme Court answered no to a video‑specific exception, approved the Fifth District’s result, and explained that any change to Florida’s summary‑judgment standard should occur prospectively via a rule amendment adopting the federal standard.
Issues
| Issue | Plaintiff's Argument | Defendant's Argument | Held |
|---|---|---|---|
| Whether Florida should adopt a video‑evidence exception allowing final summary judgment when unaltered video conclusively contradicts opposing evidence | Estate: Existing Florida law (resolve doubts against movant) precludes such an exception; video does not automatically eliminate a jury issue | Petitioners/defendants: Uncontested, unaltered video that blatantly contradicts the opposition should permit summary judgment | No special video exception; court declined to create ad hoc rule for video evidence |
| Whether Florida should adopt the federal summary‑judgment standard (Celotex/Anderson/Matsushita) | Estate: Implicitly urged retention of current Florida practice | Petitioners: Florida should adopt the federal standard that allows summary judgment when no rational jury could side with nonmovant | Court agreed Florida should adopt the federal standard but only prospectively by amending Rule 1.510 |
| Whether the Court should recede now from Florida precedent (the "slightest doubt" formulation) and reinterpret existing law in this case | Estate: Maintain the current precedents that disfavour summary judgment where any doubt exists | Petitioners: Argue existing precedent is wrong and this decision should be quashed under current law | Court declined to recede or reinterpret precedent now; refused to quash based on existing law |
| Applicability of Scott v. Harris (video blatantly contradicts party’s story) to this record | Estate: Argued that factual disputes remain despite video | Petitioners: Relied on Scott to argue that blatantly contradicted stories cannot create genuine issues | Court did not decide Scott’s applicability to the record; avoided resolving whether Harris requires a different outcome under existing Florida law |
Key Cases Cited
- Celotex Corp. v. Catrett, 477 U.S. 317 (1986) (articulates federal standard for summary judgment procedure)
- Anderson v. Liberty Lobby, Inc., 477 U.S. 242 (1986) (addresses burden and standards for genuine issues at summary judgment)
- Matsushita Elec. Indus. Co. v. Zenith Radio Corp., 475 U.S. 574 (1986) (clarifies when factual inferences defeat summary judgment)
- Scott v. Harris, 550 U.S. 372 (2007) (holds that when record, including video, blatantly contradicts a party’s story, no reasonable jury could believe it)
- Lopez v. Wilsonart, LLC, 275 So. 3d 831 (Fla. 5th DCA 2019) (appellate decision reversing trial court’s video‑based summary judgment and certifying the question)
- State v. Poole, 297 So. 3d 487 (Fla. 2020) (explains limits on receding from established precedent)