Barcelo v. Little Paket Corp.
The Third DCA reversed an order allowing Alvarez to amend to add punitive damages claims against Barcelo arising from alleged improper dividend distributions, defamation, and the ouster of Alvarez from a real estate brokerage. The court held the proffered allegations and evidence did not show intentional misconduct or gross negligence, nor conduct 'outrageous' enough to support punitive damages, and that ordinary remedies for the underlying claims sufficed.
Key facts
- Alvarez sought to amend his complaint to add punitive damages claims against Barcelo for alleged improper dividend distributions from a real estate brokerage, defamation, and wrongful ouster as an interest holder.
- The trial court granted Alvarez's motion to amend to add punitive damages claims; Barcelo appealed.
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Why it matters
The opinion is the Third DCA's third recent reaffirmation (following McLane Foodservice and River Front Master Ass'n) that Florida courts will police punitive damages proffers under section 768.72 through de novo… — full analysis with a trial
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