WARREN TECHNOLOGY, INC., ETC., APPELLANT,
v.
CARRIER CORPORATION, ETC., APPELLEE
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Warren Technology appeals a summary judgment dismissing its claims against Carrier Corporation for misrepresentation and deceptive trade practices. The Florida appellate court affirmed, finding that Warren lacked standing because it failed to demonstrate a sufficiently concrete injury beyond the loss of business.
Warren lacks standing because it failed to demonstrate that its interests would be affected by the court's resolution of the dispute. The loss of business alone is insufficient; Warren must show a cognizable injury beyond the business termination.
[1] A plaintiff must demonstrate an actual controversy and a sufficient stake or cognizable interest that would be affected by the outcome of the litigation to satisfy the re…
[2] A court's resolution of a factual dispute that would not affect a party's legally protected interests would constitute an advisory opinion, which courts are not empowered…
Previewing 2 of 4 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“A plaintiff must demonstrate the existence of an actual controversy between the plaintiff and the defendant in which plaintiff has a sufficient stake or cognizable interest which would be affected by the outcome of the litigation in order to satisfy the requirements of standing.”
Establishes the legal standard for standing that Warren failed to meet
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Join FLexlaw to unlock all legal intelligenceWarren Technology manufactures electric heaters for HVAC units and sold them to Carrier Corporation, which manufactures and installs HVAC systems. Whe…
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FLETCHER, Judge.
Warren Technology, Inc. seeks review of an adverse summary judgment in its action against Carrier Corporation on various claims of misrepresentation and deceptive -trade practices. Finding that Warren lacks standing, wé affirm.
Warren manufactures electric heaters for use in heating, ventilation and air conditioning (HVAC) units. Carrier, which manufactures and installs HVAC units, purchased electric heaters from Warren. When the heaters began to overheat and malfunction, Carrier blamed Warren and ceased doing business with them. Warren filed the instant five-count complaint against Carrier alleging that Carrier’s misleading labeling of the voltage on its unit was the actual cause of the failures.1
A plaintiff must demonstrate the existence of an actual controversy between the plaintiff and the defendant in which plaintiff has a sufficient stake or cognizable interest which would be affected by the outcome of the litigation in order to satisfy the requirements of standing. See Weiss v. Johansen, 898 So. 2d 1009, 1011 (Fla. 4th DCA 2005); Nedeau v. Gallagher, 851 So. 2d 214 (Fla. 1st DCA 2003). Although it has pointed out a disagreement between the parties, Warren has failed to demonstrate how its interests would be affected by our resolution of the issue presented. Warren has not shown that it suffered any injury caused by Carrier, other than losing the latter’s business. Carrier was free to terminate its relationship with Warren for any reason. Thus, our resolution of the factual basis for the reason given by Carrier for its termination would simply be an advisory opinion. That is not this court’s role. We, therefore, affirm the judgment below.
Affirmed.
. Warren's complaint included counts for fraudulent misrepresentations of fact (count I); negligent misrepresentations of fact— product labeling (count II); negligent misrepresentations of fact, statements of product defect (count III); defamation/trade disparagement (count IV); and violation of Florida's Deceptive and Unfair Trade Practices Act (count V). Upon Carrier's motion, the trial court granted summary judgment on all counts and a final judgment in favor of Carrier. In this appeal, Warren sought review only of the summary judgment entered on counts I, II and V on several grounds. Because we find that Warren does not have standing to pursue this action, we need not address the trial court’s ruling on the merits of these claims.
Cases With Similar Vibessemantic neighbors from the corpus
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Anthony v. Anthony, 949 So. 2d 226 (Fla. 3d DCA 2007)…venue v. Kuhnlein, 646 So. 2d 717, 720 (Fla.1994) (“[E]very case must involve a real controversy as to the issue or issues presented.”), cert. denied, 515 U.S. 1158, [*228] 115 S.Ct. 2608, 132 L.Ed.2d 853 (1995); Warren Tech., Inc. v. Carrier Corp., 937 So. 2d 1141 (Fla. 3d DCA 2006). To rule on the case at all, therefore, has no practical effect whatever and serves no purpose but the unworthy one of encouraging parties, in this case the appellant, who seem to desire to litigate domestic cases only for the sak…
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Francine Liebman v. THE City OF Miami (Fla. 3d DCA 2019)…f has a sufficient stake or cognizable interest which would be affected by the outcome of the litigation in order to satisfy the requirements of standing.” Matheson, 258 So. 3d 516, 519 (Fla. 3d DCA 2018) (citing Warren Tech., Inc. v. Carrier Corp., 937 So. 2d 1141, 1142 (Fla. 3d DCA 2006)). 5 We therefore need not reach the various constitutional questions raised on appeal. See In re Holder, 945 So. 2d 1130, 1133 (Fla. 2006) (observing that Florida courts “have long subscribed to a principle of judicial rest…
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Matheson v. Miami-Dade Cnty., 258 So. 3d 516 (Fla. 3d DCA 2018)
Previewing 3 of 6 citing cases — full citator treatment, depth of discussion, and citing context are member features.
Join FLexlaw to unlock all legal intelligenceAuthorities Cited
- Weiss v. Johansen, 898 So. 2d 1009 (Fla. 4th DCA 2005)
- Nedeau v. Gallagher, 851 So. 2d 214 (Fla. 1st DCA 2003)