Deauville Hotel Management, LLC, Etc. v. Ward
2017 WL 2348626, 219 So. 3d 949, 2017 Fla. App. LEXIS 7810 (2017)
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Rule of Law:
To establish a claim for intentional infliction of emotional distress (IIED), the defendant's conduct must be so outrageous in character and extreme in degree as to be regarded as atrocious and utterly intolerable in a civilized community. Conduct that is merely tortious, malicious, or results in significant disappointment and embarrassment, such as ruining a wedding, does not meet this exceptionally high legal standard.
Facts:
- On February 17, 2010, Kemesia Boota Ward signed a contract with Deauville Hotel Management, LLC to hold her wedding reception in the hotel's Richelieu ballroom on July 9, 2010.
- The contract stated that if the hotel was unable to provide the requested space, it would arrange for "comparable space" as a remedy.
- Nine days before the wedding, on June 30, 2010, the city of Miami Beach declared the hotel's ballrooms, including the Richelieu, unsafe and ordered them shut down.
- Deauville did not inform the Wards of the shutdown and instead unsuccessfully attempted to have the city's order lifted, even up to the day of the wedding.
- The Wards learned of the ballroom's unavailability just hours before their wedding ceremony.
- Deauville moved the reception for 190 guests to the hotel's public lobby, which was too small, lacked privacy, was subject to noise complaints, and had other hotel guests in bathing suits walking through the event.
Procedural Posture:
- Kemesia and Patrick Ward sued Deauville Hotel Management, LLC in a Florida trial court for breach of contract and intentional infliction of emotional distress.
- Following a five-day trial, a jury found in favor of the Wards on both claims.
- The jury awarded the Wards a total of $25,500 for the breach of contract and $5,000 for intentional infliction of emotional distress.
- Deauville filed a post-trial motion for a directed verdict, asking the trial court judge to overrule the jury's verdict, but the trial court denied the motion.
- Deauville (as appellant) appealed the trial court's denial of its motion to the Florida Third District Court of Appeal.
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Issue:
Does a hotel's conduct of failing to inform a couple that their contracted wedding ballroom had been condemned, and then relocating their reception on the day of the event to a cramped, public lobby, constitute conduct so extreme and outrageous as to support a claim for intentional infliction of emotional distress?
Opinions:
Majority - Luck, J.
No. The hotel's conduct was not sufficiently extreme and outrageous to sustain a claim for intentional infliction of emotional distress. To be legally actionable for IIED, conduct must be 'so outrageous in character, and so extreme in degree, as to go beyond all possible bounds of decency, and to be regarded as atrocious, and utterly intolerable in a civilized community.' While the hotel's actions were wrong, tortious, and caused the Wards significant distress by ruining their wedding day, this conduct does not rise to the level of legal outrageousness. Citing precedents, the court reasoned that if falsely accusing a minister of theft in front of his congregation or subjecting an employee to racial slurs were not deemed legally outrageous, then ruining a wedding reception, while deplorable, also falls short of this high standard. The court distinguished this case from those involving matters of life-and-death, such as an insurer withholding benefits to hasten a person's demise or a hospital covering up a death, which do meet the outrageousness threshold.
Analysis:
This case reinforces the exceptionally high bar for establishing the "outrageous conduct" element of an intentional infliction of emotional distress (IIED) claim in Florida. It clarifies that even deliberate, malicious, and emotionally devastating actions may not be legally sufficient if they do not reach the level of being 'atrocious and utterly intolerable' by societal standards. The decision serves as a significant precedent for distinguishing between conduct that is merely tortious or a breach of contract—causing foreseeable emotional harm—and conduct that is truly extreme enough to warrant a separate tort action for IIED. It guides lower courts to reserve IIED claims for the most egregious of circumstances, often involving threats to life, liberty, or fundamental human dignity, rather than for severe disappointments, however wrongfully caused.
