Glade v. Govey
The Fourth DCA reversed a nonfinal order granting leave to add a punitive-damages claim under section 768.72 in an auto-negligence case. A proffer showing only that a driver was using a cell phone, without additional evidence that the use was so reckless as to constitute a conscious disregard for others' safety, does not establish the reasonable evidentiary basis of gross negligence or intentional misconduct required to plead punitive damages.
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