SMALL v. BOARD OF COMMISSIONERS (2019)

District Court of Appeal of Florida, Third District.

Loretta SMALL, Appellant, v. BOARD OF COMMISSIONERS, Miami-Dade County Commission, Appellee.

No. 3D18-2123

Decided: October 23, 2019

Before EMAS, C.J., and SALTER and SCALES, JJ.

Garcia Law Firm, P.A., and Isidro M. Garcia (West Palm Beach), for appellant. Abigail Price-Williams, Miami-Dade County Attorney, and Marlon D. Moffett, Assistant County Attorney, for appellee.

Appellant Loretta Small appeals the trial court's September 17, 2018 order denying her motion for a new trial. After a trial in which the jury returned a verdict in favor of appellee Miami-Dade County, Small's counsel discovered that the jury foreperson had not given candid answers during voir dire about the juror's litigation history. We conclude that the trial court did not abuse its discretion in denying Small's new trial motion because the juror's litigation history was immaterial to, and remote in time from, the jury service in Small's case. Penalver v. Masomere, 178 So. 3d 533, 536 (Fla. 3d DCA 2015) (quashing an order for post-trial juror interviews because the undisclosed, prior litigation experience was not material to the case and too remote in time from the jury service).

PER CURIAM.

Was this helpful?

Why was this helpful?

Easy to understand

Solved my problem

Other

Why was this not helpful?

Missing the information I need

Too complicated / too many steps

Out of date

Other

Thank you for your feedback!

Trusted by Consumers. Recognized by AI.

As the largest network of trusted legal brands, we help firms build authority across the platforms consumers and AI systems rely on most. Our network helps attorneys strengthen visibility, credibility, and preference where legal decisions begin.

Explore the Network