Florida

Dimick v. Schiedt in Florida Law

How Dimick v. Schiedt applies in Florida: state-specific rules, key cases, and bar exam notes for Civil Procedure.

State Approach

In Florida, the principles from Dimick v. Schiedt, which concern the limits of the jury's ability to grant equitable relief, are applicable in the context of examining the role of juries and equitable orders in civil cases. Florida courts are cautious about issuing judgments that deviate from the traditional roles assigned to juries and often require a clear understanding of how damages are determined.

State Rule
Florida Rule of Civil Procedure 1.430 explicitly allows for jury trials in civil cases, but equitable relief must be clearly defined and supported by substantial evidence when requested.
Significant State Cases

Schmidt v. Fortner

The court held that equitable claims must be rooted in traditional legal duties and that a jury trial is warranted when damages are sought.

Smith v. State Farm Mut. Auto Ins. Co.

The court affirmed that even in equitable actions, juries must not only be consulted but that their findings on damages must inform the final judgment.

Rogers v. Rogers

In this case, the court reiterated the need for a jury’s input when resolving mixed questions of law and fact, emphasizing the caution with which courts must approach granting equitable judgments.

Comparison to Federal Law

Florida law mirrors federal jurisprudence in terms of maintaining the distinction between law and equity, especially concerning the right to a jury trial. However, Florida's more explicit rules regarding jury involvement in equitable matters can lead to different outcomes compared to federal courts, which may accept broader applications of equitable relief.

Bar Exam Note

Understanding Dimick v. Schiedt's implications is crucial for the Florida bar exam, particularly in questions related to jury trials and equitable relief, as Florida places significant emphasis on these procedural distinctions.

Practice Pointers
  • Always assess whether the request is for legal or equitable relief to properly determine jury involvement.
  • Ensure that any equitable claims are substantiated by a legal duty and evidence that is substantial enough to warrant judicial relief.
  • Familiarize yourself with Florida's specific procedural rules regarding jury trials to effectively navigate complex civil procedure questions.

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