The Michigan Supreme Court recently released an opinion that reversed a lower appellate court’s ruling setting aside a jury verdict in favor of an auto accident plaintiff over a jurisdictional issue. The plaintiff’s award had been vacated by the state court of appeals because the amount of damages that she claimed to have suffered at trial exceeded the $25,000 jurisdictional limit of the court where her initial complaint was filed. The state supreme court reversed the court of appeals’ decision, ruling that since the plaintiff’s complaint requested damages within the jurisdictional limit, and the final award was within that limit, the trial court had jurisdiction over her claim regardless of the evidence actually presented at trial suggesting damages in excess of the limit. Based on the most recent ruling, the plaintiff will receive the $25,000 awarded to her at trial, but she will not be compensated for any damages she incurred in excess of that amount.
The Plaintiff Was Seriously Injured in an Accident with a Driver Insured by the Defendant
The plaintiff in the case of Hodge v. State Farm Mutual Auto Insurance Company was a woman who was struck by another vehicle while driving and suffered serious injuries. After sustaining the injuries, the woman filed a personal injury lawsuit against the insurance company that represented the other driver.
The plaintiff’s suit was filed in a county district court in Michigan, which only has jurisdiction over claims demanding $25,000 or less in damages. Although the plaintiff’s complaint specifically requested damages “not in excess of $25,000,” it was apparent before trial that she would present evidence demonstrating over $25,000 in damages. The district court allowed the case to proceed to trial, and the plaintiff was awarded approximately $86,000 by the jury, which was subsequently reduced by the judge to the $25,000 jurisdictional limit.
The Defendant’s Appeal of the Verdict Was Initially Successful
After the trial, the defendant appealed the ruling to a circuit court and successfully argued that the district court did not have jurisdiction over the plaintiff’s claim, and that reducing the verdict within the jurisdictional limit after the fact was insufficient to cure the defect. The plaintiff’s argument that her pleadings only requested $25,000 in compensation was rejected by the circuit court. The state court of appeals affirmed the circuit court ruling, and the plaintiff appealed the issue to the highest state court.
The Michigan Supreme Court disagreed with the circuit court and court of appeals, ruling that the jurisdiction of the trial court has long been determined by the amount of damages requested in the complaint, rather than the amount proven at trial. Since the plaintiff’s complaint requested damages within the jurisdictional limit, and her final award did not exceed that limit, the district court properly had exercised jurisdiction over her claim.
State of Florida Court System and Jurisdictional Limits for Personal Injury Claims
The court system in Florida is similar to the Michigan system that was at issue in the Hodge case, although the jurisdictional limits are different and the courts go by different names. Florida has a four-tier state court system, which includes county courts, circuit courts, district courts, and the Florida Supreme Court. The county courts occupy the lowest rung in the Florida court system and have jurisdiction to hear minor criminal offenses, civil ordinance violations, and other civil cases that request less than $15,000. The circuit courts are the state courts of general jurisdiction that hear more serious criminal cases and civil cases with damages over $15,000, as well as appeals from the county courts. The five district courts of appeal and the Florida Supreme Court each hear appeals from the lower courts, but they do not have jurisdiction over cases that have not been previously litigated in the circuit court.
Have You Been Injured in an Accident?
If you have suffered injuries in a South Florida auto accident, a qualified Miami personal injury attorney can advise and represent you in either the county or circuit courts of the state. The experienced South Florida accident attorneys at Friedman, Rodman & Frank have successfully represented clients throughout South Florida, and our dedicated advocates know how to fight for a fair settlement or the jury award that our clients deserve. At Friedman, Rodman & Frank, we represent clients in the Miami area and throughout South Florida in accident and other personal injury or wrongful death cases. Contact us and schedule a free consultation and case review. Call toll-free at 877-448-8585 or use our online form to set up a meeting today.
More Blog Posts:
Court Affirms Judgment for Defendant in Case Filed after Fatal Skateboarding Accident, South Florida Personal Injury Lawyers Blog, published June 30, 2016.
State Supreme Court Rules that Post-Mortem Misconduct by Doctor Is Medical Malpractice, Reverses Damages Award, South Florida Personal Injury Lawyers Blog, published June 13, 2016.