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Walt Disney World v. Wood

515 So.2d 198 (1987)

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Walt Disney World v. Wood

Florida Supreme Court

515 So.2d 198 (1987)

Facts

Aloysia Wood (plaintiff) and her fiancé, Daniel Wood, visited Walt Disney World (Disney) (defendant). While at the Grand Prix attraction, Daniel rammed the rear of the car that Aloysia was driving. Aloysia was injured. Aloysia and Daniel later married. Aloysia sued Disney, and Disney sought contribution from Daniel. Under Florida state law, liability between joint tortfeasors must be determined using a standard of comparative negligence. Florida law also allows for defendants to be held jointly and severally liable for a plaintiff’s injuries. A jury found that Aloysia was 14 percent at fault, Disney was 1 percent at fault, and Daniel was 85 percent at fault. Additionally, the jury determined that Aloysia’s damages were $75,000. The trial court entered judgment against Disney for 86 percent of Aloysia’s damages. Disney appealed, arguing that because Florida has comparative negligence, joint and several liability is inherently unfair, particularly if the plaintiff is at fault. Disney suggested that damages should be apportioned according to each defendant’s relative fault. Aloysia argued that most jurisdictions that have adopted comparative negligence have retained joint and several liability, in part to ensure that a plaintiff is compensated in full for her injury regardless of the financial situation of the defendants.

Rule of Law

Issue

Holding and Reasoning (Grimes, J.)

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