1. Florida’s “two-issue rule” generally holds that an appellant cannot show reversible error when an error relates to one claim or defense and the verdict does not reveal whether the appellee prevailed on that basis or...more
Jury instructions are important in winning the case before the jury. They can also provide grounds for appeal if errors are properly preserved. The following points address the most common problems we appellate lawyers see...more
1. Always bring appellate counsel into the case before trial. If the case is important enough to try, it almost certainly will be important enough for the loser to appeal.
2. Always, at the very least, involve...more
A recent Florida appellate decision examines some new twists on Florida’s “tipsy coachman” doctrine. Before we discuss the new decision, though, it may be useful to discuss what the tipsy coachman doctrine is and where it...more
Jury instructions obviously are important in winning the case before the jury. ...more
On June 6, for the first time, the Florida Supreme Court approved standard jury instructions for use in contract and business litigation. ...more