Federal Express Corporation v. Sabbah
FedEx sought review of an order granting leave to amend to add punitive damages, arguing the January 2022 amendment to Rule 9.130(a)(3)(G) (effective April 1, 2022) allowed a non-final appeal. The Third District held that because both the order and the petition predated the rule's effective date, review was limited to the narrow certiorari standard — compliance with the procedural requirements of section 768.72 — and denied the petition because the trial court followed those procedures. Judge Gordo concurred in result only, criticizing Florida jurisprudence on the retroactive/prospective application of rule amendments as unpredictable.
Key facts
- FedEx sought appellate review of a trial court order granting leave to amend the complaint to add punitive damages claims.
- The trial court granted the amendment after finding compliance with the procedural requirements of section 768.72.
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Why it matters
This decision fixes the dividing line for punitive-damages review in the Third District: petitions/notices filed before April 1, 2022 get only narrow procedural certiorari review, while later-filed proceedings get de… — full analysis with a trial
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