Board of Trustees v. American Educational Enterprises, LLC

Summary

The Florida Supreme Court held that overbreadth alone is not a sufficient basis for common-law certiorari review of a nonfinal discovery order. The court quashed the Third District's decision and concluded that the requested financial information was relevant and discoverable because it could lead to admissible evidence concerning the value of the disputed real property, and its disclosure did not cause irreparable harm.

Holdings

1. Overbreadth alone is not a proper basis for common-law certiorari review of a nonfinal discovery order; the petitioner must establish a departure from the essential requirements of law that causes material, irreparable injury throughout the remainder of the proceedings and cannot be remedied on postjudgment appeal.
2. Financial information is discoverable when it is relevant to the disputed issues in the underlying action or is reasonably calculated to lead to admissible evidence; the requested financial information here was relevant to the property's value, the parties' valuation-related contentions, and damages issues.

Questions Presented

1. Whether overbreadth of a nonfinal discovery order, standing alone, supports common-law certiorari relief.
2. Whether the requested financial information was relevant and discoverable in the underlying action.
3. Whether disclosure of the requested financial information caused material, irreparable harm that could not be remedied on appeal.

Disposition

quashed