Boca Aircraft Maintenance, LLC v. Fifteen Group Capital, LLC
After an eight-day bench trial, the trial court awarded Fifteen Group contract damages, separate tort damages for negligence/gross negligence/fraud, and $1.5 million in punitive damages arising from defective aircraft maintenance and alleged fraudulent inducement about the mechanics' Falcon 50 experience. The Third DCA reversed, holding the independent tort rule barred the tort and punitive recovery because all damages flowed from BAM's failure to perform the maintenance contract, and remanded for the trial court to determine whether the tort compensatory damages should be reallocated as contract damages.
Key facts
- Boca Aircraft Maintenance, LLC contracted with Fifteen Group Capital, LLC to perform maintenance on a Falcon 50 aircraft; BAM allegedly made fraudulent misrepresentations about its mechanics' experience with that aircraft model.
- After an eight-day bench trial, the trial court awarded Fifteen Group contract damages, separate tort damages for negligence, gross negligence, and fraud, and $1.5 million in punitive damages.
- +2 more key facts with a free trial
Why it matters
A strong, citable application of the independent tort rule in a post-trial posture — it shows the rule is not merely a pleading-stage defense and can wipe out a $1.5 million punitive award after a full bench trial… — full analysis with a trial
🔒 Read the full opinion, holding & search the library
The full opinion PDF, the rules the court applied, our significance analysis, the background facts, and full-text search across every tracked Florida decision are available to members. Start a free 30-day trial — no credit card.
Not ready to sign up? Get the free Friday digest — the week's key Florida decisions by email, no login required.
Florida Court Tracker provides summaries of publicly available court opinions for informational and research purposes only. This is not legal advice and does not create an attorney–client relationship. Always verify holdings against the official opinion.