MARY WILLIAMS, APPELLANT,
v.
MIAMI-DADE COUNTY PUBLIC HEALTH TRUST D/B/A JACKSON MEMORIAL HOSPITAL, THE UNIVERSITY OF MIAMI, LUKE YEUNG, M.D., AND MANUEL ARCE, M.D., APPELLEES
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Mary Williams appealed a trial court's dismissal of her medical malpractice complaint based on fraud upon the court. The appellate court affirmed the dismissal, finding that Williams intentionally failed to disclose material information during discovery in a scheme designed to interfere with the court's ability to adjudicate the case fairly.
The trial court properly dismissed the complaint. The record amply supported findings that Williams' repeated non-disclosures, false statements, and omissions were intentional and designed to interfere with the administration of justice, justifying the severe sanction of dismissal under the heightened standard for fraud allegations.
[1] A trial court may dismiss a complaint for fraud upon the court when a party engages in a clear and convincing scheme calculated to interfere with the court's impartial ab…
[2] Intentional failure to disclose prior medical problems, symptoms, prior accidents, or applications for disability benefits can constitute fraud upon the court.
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Join FLexlaw to unlock all legal intelligence“engaged in a clear and convincing scheme calculated to interfere with the trial court's impartial ability to adjudicate [the] matter”
The trial court's basis for finding fraud upon the court and dismissing the complaint
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Join FLexlaw to unlock all legal intelligenceWilliams filed a medical malpractice action against Jackson Memorial Hospital, The University of Miami, and two physicians. During discovery, the tria…
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Mary Williams appeals from an order granting the defendants’, Miami-Dade County Public Health Trust d/b/a Jackson Memorial Hospital, The University of Miami, Luke Yeung, M.D., and Manuel Arce, M.D., motion to dismiss her complaint for fraud upon the court. We affirm.
The trial court dismissed Williams’ medical malpractice action in its entirety because, during the discovery process, Williams “engaged in a clear and convincing scheme calculated to interfere with the trial court’s impartial ability to adjudicate [the] matter.” In support of this conclusion, the trial court specifically found that: (1) Williams intentionally failed to disclose prior medical problems and symptoms in her deposition and interrogatory answers; (2) Williams intentionally failed to disclose her involvement in several car accidents that predated the surgery; (3) Williams intentionally failed to disclose that she had applied for disability benefits prior to the surgery; (4) Williams was not truthful with her treating physicians; and (5) Williams’ argument that her failures to disclose were caused by memory loss attributable to the defendants’ actions was incredible.
We review the trial court’s dismissal for fraud on the court for an abuse of discretion. Ramey v. Haverty Furniture Cos., 993 So.2d 1014, 1018 (Fla. 2d DCA 2008); Papadopoulos v. Cruise Ventures Three Corp., 974 So.2d 418, 419 (Fla. 3d DCA 2007). However, given the severity of the sanction of dismissal, this standard has been somewhat narrowed in application. See Ramey, 993 So.2d at 1018 (noting that in reviewing a trial court’s dismissal for fraud on the court, appellate courts consider the heightened standard applicable to allegations of fraud, and the trial court’s discretionary decision to dismiss must be well-supported by the evidence).
In this case, the record amply supports the trial court’s conclusion that Williams’ repeated non-disclosures, false statements, and omissions were intentional and designed to interfere with the administration of justice. Therefore, the trial court’s order dismissing Williams’ complaint is affirmed in all respects.
Affirmed.
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Empire World Towers, LLC v. CDR Créances, 89 So. 3d 1034 (Fla. 3d DCA 2012)…ministered only in the most egregious cases. Bertrand, 892 So. 2d at 1152. As a result, an order striking pleadings for fraud upon the court is reviewed under a “narrowed” abuse of discretion standard. Williams v. Miami-Dade Cnty. Pub. Health Trust, 17 So. 3d 859, 859 (Fla. 3d DCA 2009). The proponent of a motion to strike pleadings must prove, by clear and convincing evidence, “that a party has sen-tiently set in motion some unconscionable scheme calculated to interfere with the judicial system’s ability i…
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Faddis v. The City OF Homestead, 121 So. 3d 1134 (Fla. 3d DCA 2013)…e sanction, we review the trial court’s order under a “somewhat narrowed” abuse of discretion standard. Empire World Towers, LLC v. CDR Créances, S.A.S., 89 So. 3d 1034, 1038 (Fla. 3d DCA 2012) (citing Williams v. Miami-Dade Cnty. Pub. Health Trust, 17 So. 3d 859 (Fla. 3d DCA 2009)). The record contains competent substantial evidence to support the trial court’s determination, by clear and convincing evidence, that Faddis’s misconduct, including intentional acts of perjury on a central and material issue,…
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Leta G. Middleton v. Hager, 179 So. 3d 529 (Fla. 3d DCA 2015)…ed the evidence in determining ‘that dismissal with prejudice was warranted. Ordinarily, we would review the trial court’s determination in such a case under a narrowed abuse of discretion standard. Williams v. Miami-Dade Cnty. Public Health Trust, 17 So. 3d 859 (Fla. 3d DCA 2009) (holding that, “given the severity of the sanction of dismissal, [the abuse of discretion] standard has been somewhat narrowed in application.”) (citing Ramey v. Haverty Furniture Cos., 993 So. 2d 1014, 1018 (Fla. 2d DCA 2008) for…
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Join FLexlaw to unlock all legal intelligenceAuthorities Cited
- Sonny Ramey and Vicky Ramey v. Haverty Furniture Cos., Inc., 993 So. 2d 1014 (Fla. 2d DCA 2008)
- Captain Papadopoulos v. Cruise Ventures Three Corp., 974 So. 2d 418 (Fla. 3d DCA 2007)