Michel Valdez v. Progressive Select Insurance Company
The Third DCA affirmed, applying the principle of priority, which counsels against duplicative concurrent litigation to avoid wasting judicial resources and the risk of inconsistent judgments. The court confirmed the doctrine applies not only across states or federal/state courts but also between cases pending in different circuits or different divisions of the same circuit within Florida.
Key facts
- An insured pursued a county court action against Progressive Select Insurance Company in Miami-Dade County.
- A related case was pending concurrently, implicating the doctrine known as the principle of priority.
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Holdings
- The principle of priority—which bars unnecessarily duplicative concurrent proceedings—applies where a second-filed action is sufficiently similar in parties and issues to the prior-filed…
Why it matters
The affirmance reinforces that Florida's principle of priority reaches duplicative cases pending within the same state—even in different divisions of one circuit—and that trial courts may consider matters outside the… — full analysis with a trial
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