Trace Elements, Inc. v. Mackensen
The Florida Supreme Court quashed the Fourth DCA and held that Florida Rule of Civil Procedure 1.442(c)(3)'s apportionment requirement applies to a joint proposal for settlement even where it concerns a unified, single claim by jointly-interested plaintiffs (here, spouses who owned the property as tenants by the entireties). The Court reaffirmed strict, purpose-neutral enforcement of the apportionment rule and rejected any ad hoc exception, directing that any flaw in the rule be addressed by rule amendment rather than case-by-case exceptions.
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