Supreme Court of Florida

Amber Edwards, Petitioner v. Larry D. Thomas, M.d., Respondents — Lawson, J., Dissenting

October 26, 2017229 So. 3d 277

Summary

Justice Lawson dissents, arguing that expert reports prepared in anticipation of litigation are not "records made or received in the course of business" under Amendment 7 of the Florida Constitution and therefore should be exempt from disclosure. The dissent emphasizes the plain‑language requirement of the amendment and the work‑product doctrine.