Shaps v. Provident Life & Acc. Ins. Co.
27 Fla. L. Weekly Supp. 710, 826 So.2d 250, 2002 Fla. LEXIS 1805 (2002)
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Rule of Law:
For conflict-of-laws purposes, the burden of proof is a procedural matter governed by the law of the forum state (lex fori), not a substantive matter governed by the law controlling the contract (lex loci contractus).
Facts:
- Audrey Shaps held a disability insurance policy with Provident Life & Accident Insurance Company.
- The insurance contract was issued in New York.
- A dispute arose between Shaps and Provident regarding her eligibility for benefits for a period from September 10, 1990, through October 23, 1994.
- A second dispute arose over her eligibility for benefits for a period from September 8, 1995, through April 6, 1996.
Procedural Posture:
- Audrey Shaps sued Provident Life & Accident Insurance Company in the U.S. District Court for breach of a disability insurance contract.
- The district court ruled that because the contract was made in New York, New York's substantive law applied, and it classified Florida's burden-of-proof rule as substantive, thus making it inapplicable.
- Following a jury verdict, the district court entered a final judgment in favor of Provident.
- Shaps, as appellant, appealed the judgment to the U.S. Court of Appeals for the Eleventh Circuit.
- The Eleventh Circuit found the issue of whether Florida's burden-of-proof rule is substantive or procedural to be determinative and certified the question to the Supreme Court of Florida for resolution.
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Issue:
Is the Florida common law rule that shifts the burden of proof to the insurer to disprove an insured's continued disability a matter of substantive law for conflict-of-laws purposes?
Opinions:
Majority - Justice Quince
No. For conflict-of-laws purposes, the burden of proof is a procedural issue governed by the law of the forum, not a substantive issue governed by the law of the contract. The court first clarified that its prior discussion of this issue in Aetna Life Ins. Co. v. Fruchter (1973) was non-binding dicta because the court had discharged the writ of certiorari as improvidently granted, meaning it never ruled on the merits. Addressing the issue anew, the court distinguished between substantive law, which 'prescribes duties and rights,' and procedural law, which 'concerns the means and methods to apply and enforce those duties and rights.' Citing Walker & LaBerge, Inc. v. Halligan, the court affirmed the general principle that burden of proof requirements are procedural. As the burden of proof concerns the method of enforcing contractual rights rather than the rights themselves, it is a procedural matter controlled by the law of the forum state, which in this case is Florida.
Analysis:
This decision solidifies a key conflict-of-laws principle in Florida, definitively classifying the burden of proof as procedural. This ensures that when a case is litigated in a Florida court, Florida's procedural rules will apply, even if the substantive rights of the parties are governed by the law of another state where the contract was made. By resolving the ambiguity surrounding its prior statements in Fruchter, the court provides clarity for future choice-of-law disputes, impacting litigation strategy in contract cases with multi-state elements. The ruling prevents parties from 'importing' favorable procedural rules from other jurisdictions into a Florida courtroom.
