UNIVERSAL X RAYS, CORP., A/A/O ALFREDO DE ARMAS
v.
INFINITY AUTO INSURANCE COMPANY
AI-generated. These summaries, headnotes, and key points are machine-generated and may contain errors or omissions. Always verify against the full opinion text below. Not legal advice.
Universal X Rays, Corp. filed multiple petitions for writs of prohibition challenging trial court orders denying the company's motions to disqualify judges in Personal Injury Protection (PIP) insurance cases. The appellate court consolidated the cases and denied all petitions, holding that adverse rulings, judicial complaints, and attorney disciplinary reports do not constitute legally sufficient grounds for judicial disqualification.
The court held that adverse rulings, a judge's reporting of perceived attorney unprofessionalism to the Florida Bar, and prior complaints filed against a judge do not constitute legally sufficient grounds for judicial disqualification under Florida law.
[1] A judge's prior adverse rulings against a party do not, in themselves, constitute legally sufficient grounds for disqualification.
[2] A judge's reporting of perceived attorney unprofessionalism to The Florida Bar is legally insufficient to support judicial disqualification.
Previewing 2 of 3 headnotes on this case. FLexlaw’s editorially structured points of law — every proposition, pinpointed — are reserved for members.
Join FLexlaw to unlock all legal intelligence“the fact that a judge has ruled adversely to the party in the past does not constitute a legally sufficient ground for a motion to disqualify”
Establishes that adverse rulings are not a valid basis for disqualification
Previewing 1 of 3 key quotes on this case — the court’s exact language, pinpointed for members.
Join FLexlaw to unlock all legal intelligenceUniversal X Rays, Corp. brought consolidated PIP insurance cases against multiple insurance companies (Infinity Auto Insurance, State Farm, GEICO, Bri…
The full statement of facts, procedural history, and disposition for this case are member content.
Join FLexlaw to unlock all legal intelligence© FLexlaw, Inc. — AI-generated enrichments are proprietary. All rights reserved.
Explore caselaw by topic → Browse Motion To Disqualify Judge cases and more on FLexlaw
Third District Court of Appeal
State of Florida
Opinion filed November 13, 2024. Not final until disposition of timely filed motion for rehearing. No. 3D24-1890 Lower Tribunal No. 23-4115-SP-05 Universal X Rays, Corp., a/a/o Yensy Cuba, No. 3D24-1891 Lower Tribunal No. 23-12485-SP-05 Universal X Rays, Corp., a/a/o Alfredo de Armas, No. 3D24-1892 Lower Tribunal No. 23-52424-SP-05 Universal X Rays, Corp., a/a/o Yelenett Puig, State Farm Mutual Automobile Insurance Company, No. 3D24-1894 Lower Tribunal No. 23-4645-SP-05 Universal X Rays, Corp., a/a/o Gonzalo X Del Rio, No. 3D24-1895 Lower Tribunal No. 24-95660-SP-05 Universal X Rays, Corp., a/a/o Sandra Puente, No. 3D24-1896 Lower Tribunal No. 23-2449-SP-05 Universal X Rays, Corp., a/a/o Yalile Cabrera, No. 3D24-1898 Lower Tribunal No. 23-510-SP-05 Universal X Rays, Corp., a/a/o Eric Torres, Bristol West Insurance Company, No. 3D24-1899 Lower Tribunal No. 23-480-SP-05 Universal X Rays, Corp., a/a/o Kiro Garcia, No. 3D24-1900 Lower Tribunal No. 23-12487-SP-05 Universal X Rays, Corp., a/a/o Andreo O. Cambria, No. 3D24-1901 Lower Tribunal No. 23-1639-SP-05 Universal X Rays, Corp., a/a/o Pedro Deulofeu, Infinity Indemnity Insurance Company,
_______________
No. 3D24-1902 Lower Tribunal No. 22-1463-SP-05 Universal X Rays, Corp., a/a/o Juan Jimenez, No. 3D24-1903 Lower Tribunal No. 23-11771-SP-05 Universal X Rays, Corp., a/a/o Carina Angelo, No. 3D24-1904 Lower Tribunal No. 22-10748-SP-05 Universal X Rays, Corp., a/a/o Damaris Broche, No. 3D24-1905 Lower Tribunal No. 23-2444-SP-05 Universal X Rays, Corp., a/a/o Alexis Cabrera, No. 3D24-1906 Lower Tribunal No. 22-22226-SP-05 Universal X Rays, Corp., a/a/o Ivan Castano Figueroa,
_______________
No. 3D24-1907 Lower Tribunal No. 23-515-SP-05 Universal X Rays, Corp., a/a/o Marian T. Jimenez, No. 3D24-1908 Lower Tribunal No. 22-40432-SP-05 Universal X Rays, Corp., a/a/o Carlos Herrera, No. 3D24-1909 Lower Tribunal No. 23-11462-SP-05 Universal X Rays, Corp., a/a/o Yolaine Fajardo, Petitioner, Cases of Original Jurisdiction—Prohibition. Robert J. Lee, P.A., Robert J. Lee and Michael V. Tichenor, for petitioner. Law Office of Leslie M. Goodman & Associates, Liliana Garcia, Mylena O. Chin See, Amanda Duran, and Selena Villadiego; Law Office of Gabriel O. Fundora & Associates, Nicholas Cruz Encinas, IV, Branden V. McDaniel, and John G. Mollaghan (Tampa); Gordon Rees Scully Mansukhani, and Marcus J. Scott; Law Office of Haydee De La Rosa – Tolgyesi, Michael J. Long (West Palm Beach), and Rebeca Quintero; The Law Office of George L. Cimballa, III, and Tiffani Fox (Plantation); Law Offices of Olga Acosta Farmer, and Christine S. Robbins (Oklahoma City, OK); Law Offices of Terry M. Torres & Associates, Terry M. Torres, Stefani Hunter, Williams Mesa and Robert Phaneuf, for respondents. Before SCALES, LOBREE and GOODEN, JJ. PER CURIAM.
In these PIP cases, Petitioner Universal X Rays, Corp. challenges, via petitions for writ of prohibition, trial court orders denying Petitioner’s various motions to disqualify the trial court. We, sua sponte, consolidate the various cases and deny the petitions. See Thompson v. State, 759 So. 2d 650, 659 (Fla. 2000) (“[T]he fact that a judge has ruled adversely to the party in the past does not constitute a legally sufficient ground for a motion to disqualify.”); 5-H Corp. v. Padovano, 708 So. 2d 244, 248 (Fla. 1997) (“However, we today hold that a Florida judge’s mere reporting of perceived attorney unprofessionalism to The Florida Bar, in and of itself, is legally insufficient to support judicial disqualification. The same applies in the similar context of an attorney reporting perceived judicial unprofessionalism to the JQC.”); Fla. Code Jud. Conduct, Canon 3E(1) cmt. (“[I]f a lawyer or party has previously filed a complaint against the judge with the Judicial Qualifications Commission, that fact does not automatically require disqualification of the judge.”).
Cases With Similar Vibessemantic neighbors from the corpus
Citator
Authorities Cited
- Thompson v. State, 759 So. 2d 650 (Fla. 2000)
- 5-H Corp. v. Padovano, 708 So. 2d 244 (Fla. 1997)