Seadler v. Marina Bay Resort Condominium Ass'n, Inc.

Resolving a certified conflict, the Florida Supreme Court held that the erroneous denial of a properly preserved cause challenge in a civil case is NOT per se reversible error; harmless error review under Special v. West Boca Medical Center applies. Applying that standard, however, the Court held Marina Bay failed to prove beyond a reasonable doubt that the forced loss of a peremptory challenge did not contribute to the verdict, quashed the First DCA's decision, and remanded for a new trial in this pool-chair collapse premises case.

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