1. Abuse of Process
1. Elements
2. Defenses

2. Account Stated
1. Elements
2. Defenses

3. Accounting
1. Elements
2. Defenses

4. Assault
1. Elements
2. Defenses

5. Battery
1. Elements
2. Defenses

6. Breach: 01. Breach of Contract
1. Elements
2. Defenses

7. Breach: 02. Breach of Joint Venture Agreement
1. Elements
2. Defenses

8. Breach: 03. Breach of Promissory Note
1. Elements
2. Defenses

9. Breach: 04. Breach of Third-Party Beneficiary Contract
1. Elements
2. Defenses

10. Breach: 05. Breach of Implied in Fact Contract
1. Elements
2. Defenses

11. Breach: 06. Breach of Implied in Law Contract
1. Elements
2. Defenses

12. Breach: 07. Breach Implied Covenant of Good Faith & Fair Dealing
1. Elements
2. Defenses

13. Breach: 08. Breach of Express Warranty
1. Elements
2. Defenses

14. Breach: 09. Breach of Implied Warranty
1. Elements
2. Defenses

15. Breach: 10. Breach of Implied Warranty of Fitness for a Particular Purpose
1. Elements
2. Defenses

16. Breach: 11. Breach of Fiduciary Duty
1. Elements
2. Defenses

17. Breach: 12. Breach of Fiduciary Duty, Aiding and Abetting
1. Elements
2. Defenses

18. Building Code, Violation of
1. Elements
2. Defenses

19. Civil Conspiracy
1. Elements
2. Defenses

20. Civil Theft
1. Elements
2. Defenses

21. Contribution - Uniform Contribution Among Tortfeasors Act
1. Elements
2. Defenses

22. Conversion
1. Elements
2. Defenses

23. Copyright Infringement
1. Elements
2. Defenses

24. Declaratory Judgment
1. Elements
2. Defenses

25. Defamation by Implication
1. Elements
2. Defenses

26. Defamation Libel
1. Elements
2. Defenses

27. Defamation Per Se
1. Elements
2. Defenses

28. Defamation Slander
1. Elements
2. Defenses

29. Dog Bite Common Law
1. Elements
2. Defenses

30. Emotional Distress, Intentional Infliction
1. Elements
2. Defenses

31. Emotional Distress, Negligent Infliction
1. Elements
2. Defenses

32. Estoppel, Equitable
1. Elements
2. Defenses

33. Estoppel, Promissory
1. Elements
2. Defenses

34. False Imprisonment
1. Elements
2. Defenses

35. Florida Consumer Collection Practices Act
1. Elements
2. Defenses

36. Florida Deceptive and Unfair Trade Practices Act
1. Elements
2. Defenses

37. Forcible Entry and Detention
1. Elements
2. Defenses

38. Fraud
1. Elements
2. Defenses

39. Fraud - Constructive
1. Elements
2. Defenses

40. Fraud - Fraud in the Performance
1. Elements
2. Defenses

41. Fraud - Fraudulent Inducement
1. Elements
2. Defenses

42. Fraud - Fraudulent Misrepresentation
1. Elements
2. Defenses

43. Fraud - Negligent Misrepresentation
1. Elements
2. Defenses

44. Fraud, Aiding and Abetting
1. Elements
2. Defenses

45. Fraudulent Nondisclosure with Real Estate Transactions
1. Elements
2. Defenses

46. Gross Negligence - Employee v. Employer
1. Elements
2. Defenses

47. Implied Way of Necessity
1. Elements
2. Defenses

48. Indemnification
1. Elements
2. Defenses

49. Indemnification, Contractual
1. Elements
2. Defenses

50. Indemnification, Common Law
1. Elements
2. Defenses

51. Injunction Permanent
1. Elements
2. Defenses

52. Injurious Falsehood
1. Elements
2. Defenses

53. Interference with Child Custody
1. Elements
2. Defenses

54. Invasion of Privacy
1. Elements
2. Defenses

55. Invasion of Privacy - Appropriation
1. Elements
2. Defenses

56. Invasion of Privacy - Intrusion
1. Elements
2. Defenses

57. Invasion of Privacy - Public Disclosure of Private Facts
1. Elements
2. Defenses

58. Legal Malpractice
1. Elements
2. Defenses

59. Lien - Charging
1. Elements
2. Defenses

60. Lien - Retaining
1. Elements
2. Defenses

61. Loss of Consortium – Child
1. Elements
2. Defenses

62. Loss of Consortium – Spouse
1. Elements
2. Defenses

63. Malicious Prosecution
1. Elements
2. Defenses

64. Misleading Advertisement
1. Elements
2. Defenses

65. Money Lent
1. Elements
2. Defenses

66. Negligence
1. Elements
2. Defenses

67. Negligence Fall Down
1. Elements
2. Defenses

68. Negligence Motor Vehicle
1. Elements
2. Defenses

69. Negligence Stillbirth
1. Elements
2. Defenses

70. Negligent Destruction of Evidence
1. Elements
2. Defenses

71. Negligent Entrustment
1. Elements
2. Defenses

72. Negligent Retention
1. Elements
2. Defenses

73. Negligent Security
1. Elements
2. Defenses

74. Negligent Supervision
1. Elements
2. Defenses

75. Open Account
1. Elements
2. Defenses

76. Private Nuisance
1. Elements
2. Defenses

77. Professional Negligence
1. Elements
2. Defenses

78. Public Nuisance
1. Elements
2. Defenses

79. Public Records Act
1. Elements
2. Defenses

80. Quantum Meruit
1. Elements
2. Defenses

81. Quiet Title
1. Elements
2. Defenses

82. Replevin
1. Elements
2. Defenses

83. Rescission
1. Elements
2. Defenses

84. Slander of Title
1. Elements
2. Defenses

85. Specific Performance
1. Elements
2. Defenses

86. Statutory Way of Necessity
1. Elements
2. Defenses

87. Strict Liability
1. Elements
2. Defenses

88. Strict Liability - Design Defect
1. Elements
2. Defenses

89. Strict Liability - Failure to Warn
1. Elements
2. Defenses

90. Strict Liability - Manufacturing Defect
1. Elements
2. Defenses

91. Subrogation, Equitable
1. Elements
2. Defenses

92. Temporary Injunction
1. Elements
2. Defenses

93. Tortious Interference: 1. With Advantageous Business Relationship
1. Elements
2. Defenses

94. Tortious Interference: 2. With a Contractual Right
1. Elements
2. Defenses

95. Tortious Interference: 3. With a Dead Body
1. Elements
2. Defenses

96. Tortious Interference: 4. With the Parent-Child Relationship
1. Elements
2. Defenses

97. Trade Dress Infringement
1. Elements
2. Defenses

98. Trespass
1. Elements
2. Defenses

99. Trusts, Constructive Trust
1. Elements
2. Defenses

100. Trusts, Resulting Trust
1. Elements
2. Defenses

101. Unfair Competition
1. Elements
2. Defenses

102. Unfair Competition - Trade Name, Service Mark and Trade Mark Infringement
1. Elements
2. Defenses

103. Unjust Enrichment
1. Elements
2. Defenses

104. Usurious Transaction
1. Elements
2. Defenses

105. Worthless Check
1. Elements
2. Defenses

106. Wrongful Birth
1. Elements
2. Defenses

107. Wrongful Death
1. Elements
2. Defenses

108. Wrongful Interference with Testamentary Expectancy
1. Elements
2. Defenses

Motion for Directed Verdict

1Elements and Case Citations

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Florida Rule of Civil Procedure 1.480(a) authorizes a party to move for a directed verdict at the close of the evidence and before the case is submitted to the jury.

To obtain a directed verdict, the movant must establish that “the evidence viewed in the light most favorable to the non-moving party, shows that a jury could not reasonably differ as to the existence of a material fact and the movant is entitled to judgment as a matter of law.” Speedway, LLC v. Cevallos, 331 So. 3d 731, 735 (Fla. 4th DCA 2021). “A motion for directed verdict should not be granted unless the trial court, after viewing the evidence in the light most favorable to the non-moving party, determines that no reasonable jury could render a verdict for the non-moving party.” Houghton v. Bond, 680 So. 2d 514, 522–23 (Fla. 1st DCA 1996) (internal citations omitted) (emphasis added). “Such a motion should be considered by a trial court with extreme caution, because the granting thereof amounts to a holding that the non-moving party’s case is devoid of probative evidence.” Id.

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      Florida Rule of Civil Procedure 1.480(a) authorizes a party to move for a directed verdict at the close of the evidence and before the case is submitted to the jury.

      To obtain a directed verdict, the movant must establish that “the evidence viewed in the light most favorable to the non-moving party, shows that a jury could not reasonably differ as to the existence of a material fact and the movant is entitled to judgment as a matter of law.” Speedway, LLC v. Cevallos, 331 So. 3d 731, 735 (Fla. 4th DCA 2021). “A motion for directed verdict should not be granted unless the trial court, after viewing the evidence in the light most favorable to the non-moving party, determines that no reasonable jury could render a verdict for the non-moving party.” Houghton v. Bond, 680 So. 2d 514, 522–23 (Fla. 1st DCA 1996) (internal citations omitted) (emphasis added). “Such a motion should be considered by a trial court with extreme caution, because the granting thereof amounts to a holding that the non-moving party’s case is devoid of probative evidence.” Id.

      For example, a motion for a directed verdict is not always appropriate in negligence cases. “[I]n negligence cases . . . directed verdict motions should be treated with special caution because it is the function of the jury to weigh and evaluate the evidence.” Etheredge v. Walt Disney World Co., 999 So. 2d 669, 671-72 (Fla. 5th DCA 2008). “‘[W]hile a directed verdict is appropriate in cases where the plaintiff has failed to provide evidence that the negligent act more likely than not caused the injury, it is not appropriate in cases where there is conflicting evidence as to the causation or the likelihood of causation.” Martinez v. Lobster Haven, LLC, 320 So. 3d 873, 879 (Fla. 2d DCA 2021).

      The standard of review on appeal for an order granting or denying a motion for directed verdict is de novo. However, the appellate court reviewing an order granting a motion for directed verdict must view all evidence and inferences of fact in the light most favorable to the nonmoving party and may only affirm where no proper view of the evidence could sustain a verdict in favor of the nonmoving party.; Elliott v. Elliott, 58 So. 3d 878, 880 (Fla. 1st DCA 2011); Merritt v. OLMHP, LLC, 112 So. 3d 559, 562 (Fla. 2d DCA 2013); Island Travel & Tours, Ltd., Co. v. MYR Indep., Inc., 300 So. 3d 1236, 1238-39 (Fla. 3d DCA 2020); Banco Espirito Santo Intern., Ltd. v. BDO Intern., B.V., 979 So. 2d 1030, 1032 (Fla. 3d DCA 2008); Contreras v. U.S. Sec. Ins. Co., 927 So. 2d 16, 20 (Fla. 4th DCA 2006); Andrews v. Direct Mail Exp., Inc., 1 So. 3d 1192, 1193 (Fla. 5th DCA 2009).


      FLORIDA STATE COURTS

      Supreme Court: S. Wood Indus. v. Fla. Carolina Lumber Co., 84 So. 2d 589, 589-90 (Fla. 1956) (reversing directed verdict for the defendant); Meruelo v. Mark Andrew of Palm Beaches, Ltd., 12 So. 3d 247, 250-52 (Fla. 4th DCA 2009) (“revers[ing] the trial court’s denial of. . .motion for directed verdict . . . and remand[ing] for entry of a directed verdict.)

      First District: Turner v. Gamiz, 327 So. 3d 1253, 1255-56 (Fla. 1st DCA 2021) (reversing directed verdict for appellee); DZE Corp. v. Vickers, 299 So. 3d 538, 539-42 (Fla. 1st DCA 2020) (“revers[ing] with directions to grant a directed verdict”).

      Second District: Roman v. Sos, 393 So. 3d 1263, 1266 (Fla. 2d DCA 2024); Olguin v. Olguin, 2022 WL 1654814, *1-5 (Fla. 2d DCA May 25, 2022) (reversing directed verdict); Merritt v. OLMHP, 112 So. 3d 559, 561-563 (Fla. 2d DCA 2013) (affirming order granting motion for directed verdict).

      Third District: People's Tr. Ins. Co. v. Hernandez, 400 So. 3d 744, 747 (Fla. 3d DCA 2024); Forbes v. Millionaire Gallery, Inc., 335 So. 3d 1260, 1262-63 (Fla. 3d DCA 2022) (affirming denial of directed verdict);  Hernandez v. Mishali, 319 So. 3d 753, 757-62 (Fla. 3d DCA 2021)  (reversing directed verdict).

      Fourth District: Anchor Prop. and Cas. Ins. Co. v. Trif., 322 So. 3d 663, 669-77 (Fla. 4th DCA. 2021) (affirming denial of directed verdict); Gyongyosi v. Miller, 80 So. 3d 1070, 1072-78 (Fla. 4th DCA 2012) (affirming order granting directed verdict).

      Fifth District: Andrews v. Direct Mail Exp., Inc., 1 So. 3d 1192, 1193-94 (Fla. 5th DCA 2009) (reversing directed verdict);  McDonald v. McGowan, 402 So. 2d 1197, 1199-1201 (Fla. 5th DCA 1981) (reversing directed verdict and affirming directed verdict on counterclaim).


      2 Issues And Considerations

      (1) “‘[A] party cannot seek judgment in accordance with a previously-made motion for directed verdict unless that party has actually asserted the grounds raised in the motion for directed verdict made at the conclusion of the evidence in the case.’” Martinez v. Lobster Haven, LLC, 320 So. 3d 873, 879 (Fla. 2d DCA 2021).

      (2) “[O]ne who submits his cause to the trier of fact without first moving for directed verdict at the end of all evidence has waived the right to make that motion.” Strickland v. State Farm Mut. Auto. Ins. Co., 323 So. 3d 783, 785 (Fla. 1st DCA 2021) citing Prime Motor Inns, Inc. v. Waltman, 480 So. 2d 88, 90 (Fla. 1985).

      (3) “Because the rule treats the denial of a motion for directed verdict at the close of the evidence as a reservation of ruling, in order to preserve the point for appellate review it is necessary to make an appropriate post-trial motion.” Brown v. State, 940 So. 2d 609, 610 (Fla. 4th DCA 2006).

      (4) “It is appropriate to direct a verdict for the defendant only when the evidence considered in its entirety and the reasonable inferences to be drawn therefrom fail to prove the plaintiff’s case under the issues made by the pleadings.” Rosa v. Dep’t of Child. & Families, 915 So. 2d 210, 211 (Fla. 1st DCA 2005).

      (5) “When determining whether a directed verdict is appropriate, the reviewing court may not reweigh the evidence or substitute its judgment concerning credibility of the witnesses for that of the trier of fact.Sanders v. ERP Operating Ltd. P’ship, 157 So. 3d 273, 280 (Fla. 2015).

      [/MM_Access_Decision]
      The Florida Rules of Civil Procedure The Florida Rules of Appellate Procedure
      The Florida Evidence Code The Federal Appellate Rules of Civil Procedure
      Rules Regulating The Florida Bar The Local Rules of the Southern District of Florida
      The Federal Rules of Civil Procedure The Local Rules of the Middle District of Florida
      Federal Rules of Evidence The Local Rules of the Northern District of Florida
      Florida Rules of Judicial Administration Florida Standard Jury Instructions