Shandalyn Sanders v. Erp Operating Limited Partnership

Summary

The Supreme Court of Florida quashed the Fourth District's reversal of a jury verdict in a negligent-security wrongful-death action. It held that the evidence, viewed favorably to the estate, permitted a reasonable inference that the apartment complex's inoperable security gate and other security failures more likely than not substantially contributed to the murders, so causation remained a jury issue and a directed verdict was improper. Justice Polston, dissenting, would have discharged the case for lack of express and direct conflict jurisdiction, concluding that the Fourth District correctly applied the governing causation rule.