Davis v. Monahan

832 So. 2d 708 (2002)

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Davis v. Monahan

Florida Supreme Court
832 So. 2d 708 (2002)

  • Written by Liz Nakamura, JD

Facts

Helen Monahan (defendant) suffered from senile dementia, and her niece, Elizabeth Davis (plaintiff), handled Monahan’s financial affairs. Between 1990 and 1992, Davis misappropriated nearly $600,000 of Monahan’s assets. Monahan did not discover the misappropriations until 1995, when Davis wrongfully and unsuccessfully attempted to transfer partial title to Monahan’s Florida condominium. In 1997, Monahan sued Davis on six counts related to the wrongful taking, including breach of fiduciary duty and unjust enrichment. Although a four-year statute of limitations applied to all of Monahan’s claims, Monahan argued that her claims were not time-barred because she did not discover the misappropriations until 1995. The trial court disagreed and dismissed Monahan’s case, holding that Monahan’s claims were time-barred because the misappropriations occurred more than four years before Monahan filed her complaint. Monahan appealed. The appellate court reversed, holding that the delayed-discovery doctrine delayed the accrual of Monahan’s claims, and the running of the statute of limitations, until Monahan discovered the misappropriations in 1995. Davis appealed to the Florida Supreme Court.

Rule of Law

Issue

Holding and Reasoning (Quince, J.)

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