Annesser Armenteros, PLLC v. Caparo
On a non-final appeal under Rule 9.130(a)(3)(G), the Third District reviewed de novo an order allowing a counterclaimant to amend to assert punitive damages against a law firm and one of its attorneys, based on allegations that the firm aided and abetted a client's fraud by drafting and recording a fraudulent quit claim deed. The court affirmed as to the firm, because the proffer showed intentional misconduct by managing partner John Annesser sufficient to support direct corporate punitive liability, but reversed as to individual attorney Miguel Armenteros, whose name appeared in the deed's 'prepared by/return to' block only by an associate's inadvertence and who had no involvement in the representation.
Key facts
- Law firm Annesser Armenteros, PLLC and attorney Miguel Armenteros were sued by a counterclaimant who alleged they aided and abetted the client's fraud by drafting and recording a fraudulent quit claim deed.
- The trial court granted the counterclaimant's motion to amend the complaint to assert punitive damages against both the firm and Armenteros.
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Why it matters
The opinion is a practical illustration of individualized punitive-damages gatekeeping: counsel opposing a section 768.72 motion should insist on defendant-specific proffered evidence, since an entity's exposure via a… — full analysis with a trial
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