DESIGNS FOR VISION, INC., AND EDWARD BROWN, APPELLANTS,
v.
AMEDAS, INC., A FLORIDA CORPORATION, APPELLEE
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Designs for Vision, Inc. (DVI) and Edward Brown appeal jury verdicts awarding damages to Amedas, Inc. for breach of employment contract and tortious interference. The appellate court affirms the jury's liability findings but reverses and remands regarding the damages structure and punitive damages award.
The court affirms that sufficient evidence supported the jury's findings of breach of contract by Brown and tortious interference by DVI. However, the court reverses the separate compensatory damage awards, holding that when one party breaches a contract and another tortiously interferes with that breach, the defendants should be held jointly and severally liable for the single amount of proven damages. The court also reverses the punitive damages award, finding the evidence did not support the extreme conduct required for such damages.
[1] Sufficient evidence can support a jury's finding of breach of contract and tortious interference with that contract.
[2] When a party breaches a contract and the breach is caused by the tortious interference of another party, the injured party should be awarded damages jointly and severally…
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Join FLexlaw to unlock all legal intelligence“When a party breaches a contract (Brown), and the breach results from the tortious interference of another party (DVI), the proper procedure is to make the two jointly and severally liable for the damages resulting from the breach.”
Establishes the key holding regarding proper liability structure when breach and tortious interference are intertwined
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Join FLexlaw to unlock all legal intelligenceEdward Brown was employed by Amedas, Inc., which served as the Florida sales representative for DVI, a medical equipment manufacturer. Brown breached …
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BLUE, Judge.
Designs for Vision, Inc. (DVI) and Edward Brown appeal jury verdicts rendered against them and in favor of Amedas, Inc. Amedas served as the Florida sales representative for DVI, a medical equipment manufacturer. The verdict against Brown, a former Amedas employee, awarded compensatory damages for breach of his employment contract with Amedas. The verdict against DVI was for compensatory and punitive damages based on tortious interference with the same employment contract.
We hold there was sufficient evidence to support the jury’s finding regarding Brown’s breach of contract and DVI’s tortious interference. We conclude, however, that the compensatory damages were improperly imposed against each of the defendants separately and that the evidence did not support the award of punitive damages.
First, the compensatory damages proven at trial resulted from Brown’s breach of contract. No evidence was admitted or argued regarding independent damages arising from the tortious interference claim against DVI. The final judgment, however, awarded Amedas $27,000 against Brown and $27,000 against DVI. As fact-finders, we might have decided otherwise; but we hold there is record support for the jury’s determination that Amedas sustained $27,000 in damages. Nevertheless, awarding these damages against each defendant separately creates a windfall for Amedas by doubling the proven damages. When a party breaches a contract (Brown), and the breach results from the tortious interference of another party (DVI), the proper procedure is to make the two jointly and severally liable for the damages resulting from the breach. Insurance Field Servs., Inc. v. White & White Inspection and Audit Serv., Inc., 384 So. 2d 303 (Fla. 5th DCA 1980); Kahlert v. Tom Heller, Inc., 557 So. 2d 111 (Fla. 4th DCA 1990). Thus, the separate damage awards were error. Second, we have reviewed the record and determined that the evidence failed to prove the level of extreme conduct which would justify an award of punitive damages. American Cyanamid Co. v. Roy, 498 So. 2d 859 (Fla.1986).
Therefore, we affirm the jury verdicts to the extent they find that Brown breached his contract with Amedas and that DVI tortiously interfered with that contract. We reverse the compensatory damages against each of the defendants separately and remand for the trial court to enter a judgment of $27,000 in favor of Amedas and jointly and severally against Brown and DVI. We also reverse the punitive damage award against DVI and remand for the trial court to enter judgment accordingly.
Affirmed in part, reversed in part, and remanded.
CAMPBELL, A.C.J., and SCHOONOVER, J., concur.
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Whitby v. Infinity Radio Inc., 951 So. 2d 890 (Fla. 4th DCA 2007)…lants argue next that the trial court erred in entering the judgment against them in the amount of $575,000 each, for a total compensatory damages award of 2.3 million dollars.6 We agree. Appellants rely on Designs for Vision, Inc. v. Amedas, Inc., 632 So. 2d 614 (Fla. 2d DCA), rev. denied, 639 So. 2d 975 (Fla. 1994). There, the Second District concluded that “When a party breaches a contract ... and the breach results from the tor-tious interference of another party ... the proper procedure is to make the t…
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Join FLexlaw to unlock all legal intelligenceAuthorities Cited
- Ins. Field Servs., Inc. v. White & White Inspection & Audit Serv., Inc., 384 So. 2d 303 (Fla. 5th DCA 1980)
- Am. Cyanamid Co. v. ROY, 498 So. 2d 859 (Fla. 1986)
- U.S.P. Prods., Inc. v. Brown, 557 So. 2d 111 (Fla. 3d DCA 1990)