United States v. Stevens

Summary

The Supreme Court of Florida answered an Eleventh Circuit-certified question concerning whether laboratories handling ultrahazardous materials owe a duty of reasonable care to the general public to prevent unauthorized interception and dissemination of those materials. The court held that such a duty exists under Florida negligence law, applying the foreseeable-zone-of-risk analysis and Restatement (Second) of Torts sections 302, 302A, and 302B. A dissent would have analyzed the issue under strict liability principles governing ultrahazardous activities and limited the duty to persons the laboratory should recognize as likely to be harmed.

Holdings

1. Under Florida negligence law, a laboratory that manufactures, grows, tests, or handles ultrahazardous materials owes a duty of reasonable care to members of the general public to avoid unauthorized interception and dissemination of those materials.
2. Because the first part of the certified question was answered affirmatively, the court did not address whether a duty would arise from an inadequate response to a history of dangerous materials going missing or being stolen.

Questions Presented

1. Under Florida negligence law, does a laboratory that manufactures, grows, tests, or handles ultrahazardous materials owe a duty of reasonable care to members of the general public to avoid unauthorized interception and dissemination of those materials?
2. Whether the court needed to reach the alternative question concerning a duty arising from an inadequate response to a history of dangerous materials going missing or being stolen.

Disposition

remanded