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 \u2014 compliance with the procedural requirements of section 768.72 \u2014 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.
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