MARK THORKELSON
v.
SOHO HOUSE BEACH HOUSE LLC
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Defamation by implication is not a separate cause of action but is subsumed within the tort of defamation.
[1] Defamation by implication is not a separate cause of action but is subsumed within the tort of defamation under Florida law.
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Join FLexlaw to unlock all legal intelligence“defamation by implication is 'subsumed within the tort of defamation' and not a separate cause of action”
The court cited Jews for Jesus, Inc. v. Rapp, 997 So. 2d 1098, 1108 (Fla. 2008) to establish the legal principle governing defamation claims.
Mark Thorkelson appealed a decision from the Circuit Court for Miami-Dade County. The case involved claims related to defamation.…
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Third District Court of Appeal
State of Florida
Opinion filed July 16, 2026.
Not final until disposition of timely filed motion for rehearing.
No. 3D25-1627
Lower Tribunal No. 21-3284-CA-01
Mark Thorkelson,
Appellant,
vs.
Soho House Beach House LLC,
Appellee.
An Appeal from the Circuit Court for Miami-Dade County, Reemberto
Diaz, Judge.
Mark Thorkelson, in proper person.
Wallen Kelley, and John D. Golden and Jennifer A. Golden, for
appellee.
Before SCALES, C.J., and BOKOR and GOODEN, JJ.
PER CURIAM.
Affirmed. See In re Amends. to Fla. Rule of Civ. Proc. 1.510, 317 So. 3d 72, 77 (Fla. 2021) (“To comply with [Rule 1.510(a)] . . . . The court must state the reasons for its decision with enough specificity to provide useful guidance to the parties and, if necessary, to allow for appellate review."); Jones v. Ervolino, 339 So. 3d 473, 475 (Fla. 3d DCA 2022) (“Busy trial judges need not write lengthy opinions, but must take reasonable steps to ensure the parties and appellate courts are informed as to the reasons for granting or denying the motion on which their rulings rest . . . ."); see also Jews for Jesus, Inc. v. Rapp, 997 So. 2d 1098, 1108 (Fla. 2008) (holding that defamation by implication is “subsumed within the tort of defamation" and not a separate cause of action).
2
Cases With Similar Vibessemantic neighbors from the corpus
Citator
Authorities Cited
- Jews FOR Jesus, Inc. v. Rapp, 997 So. 2d 1098 (Fla. 2008)
- Jones v. Ervolino, 339 So. 3d 473 (Fla. 3d DCA 2022)