Sylvia H. Walbolt

Sylvia H. Walbolt

Carlton Fields Jorden Burt

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Pitfalls Of The Verdict Form And The Two-Issue Rule

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

11/11/2013 - Appeals Jury Verdicts Reversible Error Two-Issue Rule

23 Tips For Improved Jury Instructions

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

8/30/2013 - Appeals Jury Instructions Litigation Strategies Objection Procedures

New Twists On Florida’s ‘Tipsy Coachman’ Doctrine

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

8/27/2013 - Appeals Trial Court Orders

Tips For Preserving The Record: The “Opening The Door” Opportunity And The Art Of The Proffer

Trial courts make evidentiary rulings both before and during trial, and trial lawyers should be alert to the opportunity to request the court to revisit its earlier rulings during the course of trial. ...more

7/31/2013 - Appeals Appellate Record Evidentiary Rulings Offer of Proof Proffer Agreement

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