James Seadler v. Marina Bay Resort Condominium Association, Inc.

Summary

The court held that an erroneously denied cause challenge in a civil case is reviewed under harmless error analysis rather than treated as per se reversible error, even when properly preserved. Applying the beneficiary's burden to show beyond a reasonable doubt that the error did not contribute to the verdict, the court concluded that Marina Bay failed to establish harmlessness because the lost peremptory challenge could have affected the seating of Juror 22. The court quashed the First District's decision and remanded for a new trial.