Florida Department of Environmental Protection, Division of Recreation and Parks v. Estate of Jana Sophie Zoll
A German exchange student was killed crossing State Road A1A between the two halves of Gamble Rogers Memorial State Recreation Area. Her estate sued FDEP and FDOT, alleging they knowingly created a dangerous intersection lacking illumination and traffic signals and failed to warn. The Fifth DCA reversed the denial of the agencies' motion to dismiss, holding the amended complaint's own allegations conclusively established that the challenged conduct was discretionary, planning-level decision-making protected by sovereign immunity.
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