Summary
The Florida Supreme Court held that statutory setoff provisions do not apply when a settling defendant is found not liable for the plaintiff's injury. Because the jury found Schnepel 100% liable and exonerated Glock, Schnepel was not entitled to reduce the economic-damages award by Gouty's settlement with Glock. The court quashed the First District's decision and disapproved the Second District's Lauth decision to the extent inconsistent.
Topics
Practice areas
Questions Presented
- Whether Florida's statutory setoff provisions require reducing a nonsettling defendant's award of economic damages by settlement proceeds paid by a settling defendant whom the jury found not liable.
Holdings
- Florida's statutory setoff provisions do not apply when the settling defendant is found not liable for the plaintiff's injury. Because Schnepel was found 100% liable and Glock was exonerated, Schnepel was not entitled to a setoff for Gouty's settlement with Glock.
Key quotations
“We agree with Gouty and hold that the setoff statutes are inapplicable to a settling defendant who is found to have no liability.” (at 960)
“We conclude, following our reasoning in Wells, that the applicability of the setoff statutes is predicated on the existence of other tortfeasors who are liable for the same injury as the settling party.” (at 965)
Factual background
John Gouty was injured by a bullet from J. Alan Schnepel's gun and sued Schnepel and gun manufacturer Glock, Inc. Before trial, Gouty settled with Glock for $137,500 and released his claims against Glock. The jury found Schnepel 100% liable, found Glock not liable, and awarded Gouty $250,000 in total damages, including $125,000 in economic damages. Schnepel sought a setoff for the Glock settlement, but the trial court denied the request.
Procedural history
Gouty sued Schnepel and Glock, Inc. after being injured by a bullet from Schnepel's gun. Gouty settled and released his claims against Glock for $137,500 before trial. The jury found Schnepel 100% liable, exonerated Glock, and awarded $125,000 in economic damages as part of a $250,000 total award. The trial court denied Schnepel's motion for a settlement setoff, but the First District reversed and held that Schnepel was entitled to a setoff for the economic damages. The Supreme Court quashed the First District's decision and remanded.
Remand instructions
The case was remanded to the lower court for proceedings consistent with the opinion.