Supreme Court of Florida

Valerie Audiffred, Petitioner v. Thomas B. Arnold, Respondent

April 16, 201540 Fla. L. Weekly Supp. 199

Summary

The Florida Supreme Court affirmed the First District Court of Appeal’s reversal of the award of costs and attorney’s fees, holding that a settlement proposal by a single offeror that resolves claims of additional parties is a joint proposal requiring apportionment under Rule 1.442(c)(3) and Statute 768.79. The Court found the proposal ambiguous and invalid for failing to apportion the amount between the two plaintiffs. Justice Canada dissented, arguing the Court lacked jurisdiction because there was no express and direct conflict of decisions.