Miami Beach Healthcare Group, Ltd. v. Robert Bruce Donoway, M.D.
The Fourth DCA reversed the denial of a motion to transfer venue, holding that all of the plaintiff's claims—including the tort claims—accrued in Miami-Dade County where the peer review process and revocation of hospital privileges occurred. Because the plaintiff offered no evidence to rebut the defendants' affidavit after the burden shifted, the case had to be transferred to the Eleventh Judicial Circuit.
Key facts
- A surgical oncologist sued a hospital group after his medical staff privileges at Aventura Hospital (Miami-Dade County) were suspended and revoked following a peer review investigation.
- The amended complaint alleged eight counts including injunctive and declaratory relief, breach of contract, constructive fraud, and common law fraud.
- +2 more key facts with a free trial
Holdings
- For venue purposes under section 47.011, a tort claim accrues where the last event necessary to make the defendant liable took place—i.e., where the plaintiff first suffers injury—not where…
- +1 more holding with a free trial
Why it matters
This decision reinforces the rule that downstream economic damages do not control venue accrual analysis—practitioners must locate the place where the operative tortious conduct was completed, not where the client's… — full analysis with a trial
Read the full opinion, holdings & search — free for 30 days
The full opinion PDF, the rules the court applied, our significance analysis, the background facts, and full-text search across every tracked Florida decision — in your hands.
- Search every tracked Florida decision in seconds
- Save, tag & file the cases that matter into your own library
- Read the full plain-English analysis and holdings
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.