American Prime Title Services, LLC v. Zhi Wang
A non-settling defendant sought certiorari review of an order denying its motion to compel disclosure of the amounts of co-defendants' settlements with the plaintiff, arguing the ruling eviscerated its setoff defense. The Third District dismissed for lack of jurisdiction, holding that because setoff is determined by the court after a liability finding and before judgment, and the trial court expressly left the door open to revisit disclosure post-liability, the petitioner showed no harm irremediable on plenary appeal. Judge Scales dissented, would have denied rather than dismissed, and would certify conflict with Allen (2d DCA) and Wal-Mart v. Strachan (4th DCA).
Key facts
- American Prime Title Services, LLC sought certiorari review after the trial court denied its motion to compel disclosure of settlement amounts paid by co-defendants to the plaintiff.
- American Prime Title Services argued that withholding settlement information undermined its ability to pursue a setoff defense, which reduces its liability by the amounts already recovered from other defendants.
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