Walt Disney World v. Wood
515 So. 2d 198 (1987)
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Rule of Law:
The judicial adoption of a pure comparative negligence system does not, by itself, abolish the common law doctrine of joint and several liability. The determination of whether to retain, modify, or eliminate joint and several liability is a complex public policy decision best addressed by the legislature.
Facts:
- In November 1971, Aloysia Wood was driving a vehicle at the grand prix attraction at Walt Disney World (Disney).
- Her fiance, Daniel Wood, was driving another vehicle on the same attraction.
- Daniel Wood's vehicle rammed into the rear of the vehicle Aloysia Wood was driving.
- As a result of the collision, Aloysia Wood sustained injuries.
- Aloysia and Daniel Wood subsequently married prior to the lawsuit being filed.
Procedural Posture:
- Aloysia Wood sued Walt Disney World Co. (Disney) in a Florida trial court for negligence.
- Disney filed a third-party claim against Daniel Wood, seeking contribution.
- A jury returned a verdict finding Aloysia Wood 14% at fault, Daniel Wood 85% at fault, and Disney 1% at fault, with total damages of $75,000.
- The trial court entered judgment against Disney for 86% of the damages, holding it jointly and severally liable for both its and Daniel Wood's share of the fault.
- Disney's motion to alter the judgment to hold it liable for only its 1% of fault was denied by the trial court.
- Disney, as appellant, appealed the judgment to the Fourth District Court of Appeal.
- The appellate court affirmed the trial court's decision but certified a question of great public importance to the Supreme Court of Florida.
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Issue:
Does the judicial adoption of pure comparative negligence in Florida require the abolition of the doctrine of joint and several liability?
Opinions:
Majority - Grimes, J.
No, the adoption of pure comparative negligence does not require the abolition of joint and several liability. While acknowledging the logical argument that liability should be proportionate to fault, the court affirmed its precedent in Lincenberg v. Issen, which upheld the doctrine. The court recognized that while some states have judicially abolished joint and several liability post-comparative negligence, the majority have retained it for public policy reasons, such as ensuring full compensation for injured plaintiffs. Concluding that the issue involves complex, competing interests, the court held that the viability of the doctrine is a matter best decided by the legislature, which had recently enacted tort reform legislation that modified, but did not eliminate, the doctrine.
Dissenting - McDonald, C.J.
Yes, the adoption of pure comparative negligence logically requires the abolition of joint and several liability. The dissent argues that it is a 'mismatch of legal concepts' to apportion fault for a plaintiff's recovery while holding defendants jointly liable without regard to their individual percentage of fault. The principles of Hoffman v. Jones, which established comparative negligence, dictate that each party should pay for the proportion of damages they caused. The traditional justifications for joint and several liability, such as the 'indivisible injury' theory, are obsolete fictions now that juries routinely allocate fault. Forcing a defendant who is 1% at fault to pay 86% of the damages is unjust and contrary to the core principle of comparative fault, which is to predicate liability on blameworthiness, not solvency.
Dissenting - Overton, J.
Yes, the court should abolish the doctrine. The dissent argues that the majority's decision to defer to the legislature is an 'abdication of our responsibility' and 'hypocritical.' Because the court judicially created the doctrine of joint and several liability and judicially adopted comparative negligence, it is the court's duty to address the resulting logical inconsistency. To force a tortfeasor who caused only one percent of an injury to pay eighty-six percent of the damages is fundamentally unjust.
Analysis:
This case illustrates the judiciary's reluctance to extend its common-law-making authority in tort law following the landmark adoption of comparative negligence. By deferring to the legislature, the Florida Supreme Court established a significant boundary on judicial tort reform, signaling that complex liability allocation rules with broad public policy implications are better handled through the legislative process. This decision solidified the status quo, placing the onus on lawmakers to address the perceived inequities of joint and several liability in a comparative fault system. It highlights the tension between judicial legal logic (as argued by the dissent) and legislative public policy prerogatives in shaping tort law.
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