Florida

Adickes v. S.H. Kress & Co. in Florida Law

How Adickes v. S.H. Kress & Co. applies in Florida: state-specific rules, key cases, and bar exam notes for Civil Procedure.

State Approach

Florida adheres to the principle established in Adickes regarding the adequacy of evidence for establishing a genuine issue of material fact. In Florida, a party opposing a summary judgment must present sufficient evidence to demonstrate that there is a genuine dispute for trial.

State Rule
In Florida, the rule governing summary judgment is found in Florida Rule of Civil Procedure 1.510, which requires that the party moving for summary judgment show there is no genuine issue of material fact and that they are entitled to judgment as a matter of law.
Significant State Cases

Sullivan v. Florida Power & Light Co.

The court emphasized the burden on the party opposing summary judgment to produce evidence sufficient to create a genuine issue of material fact.

Murray v. City of Port Orange

This case reaffirmed that merely raising issues in a motion to oppose summary judgment is not enough without supporting evidence.

Holl v. Talcott

The Florida Supreme Court held that the party moving for summary judgment bears the initial burden but once that burden is met, the opposing party must come forward with sufficient evidence.

Comparison to Federal Law

Florida's approach to summary judgment partially mirrors the federal standard set forth in Rule 56, emphasizing the necessity for evidence to dispute material facts. However, Florida law places a more stringent burden on the party opposing summary judgment, which may require more concrete evidence earlier in the legal process.

Bar Exam Note

Understanding the application of Adickes principles in Florida is important for the Florida bar exam, especially in questions related to civil procedure and summary judgment.

Practice Pointers
  • Always assess the quality and quantity of evidence when opposing a summary judgment motion.
  • Keep in mind that Florida law may impose stricter evidence requirements than federal law.
  • Practice drafting statements of genuine issues of material fact that are well-supported by evidence.
  • Familiarize yourself with recent Florida cases that have interpreted the summary judgment standard.
  • Consider strategic implications of summary judgment motions on the overall timeline of litigation.

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