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3rd DCAOctober 28, 2026Reversed and Remanded⭐ Notable

Victoria Friend LLC v. Tamiami Airport Service Center, Inc.

Case No. 3D2026-0944

The trial court denied leave to amend to add a punitive damages claim because the proffered conduct did not 'rise to the level of punitives in terms of shocking, outrageous, and immoral.' The Third District reversed, holding that section 768.72(1) requires only a reasonable evidentiary showing that a reasonable person could conclude the defendant engaged in 'intentional misconduct' or 'gross negligence' as statutorily defined, and that the trial court applied a standard the statute does not prescribe.

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Key facts

  • Victoria Friend LLC sought leave to amend its complaint to add a punitive damages claim against Tamiami Airport Service Center, Inc.
  • The trial court denied the motion to amend, finding the alleged conduct did not rise to the level of 'shocking, outrageous, and immoral' conduct warranting punitive damages.
  • +2 more key facts with a free trial

Why it matters

This decision applies the Florida Supreme Court's recent Perlmutter construction of section 768.72 and gives litigators a citable reversal for trial courts that import common-law 'shocking, outrageous, and immoral'… — full analysis with a trial

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