In a Per Curiam Memorandum decision, a panel of Florida's Third District Court of Appeal spoke volumes by saying little.
In Strems Law Firm, P.A. v. Citizens Prop. Ins. Corp., Nos. 3D20-919 & 3D20-920, 2021 WL 2559098 (Fla. 3d DCA June 23, 2021) (stated "NOT FINAL"), the panel PCA or "Per Curiam Affirmed" opinion cited to cases that tell a tale of the long reach of bad faith law.
The panel opinion cited three Florida Supreme Court cases approvingly and gave a parenthetical for each one. In particular, for one Supreme Court decision the Third District panel observed that “[A] trial court possesses the inherent authority to impose attorneys’ fees against an attorney for bad faith conduct.” 2021 WL 2559098, at *1 (emphasis added).
The other Florida Supreme Court decisions cited in the PCA opinion involved Fla. R. Civ. P. 1.540, which concerns relief from judgments, and the inherent discretion of trial judges to dismiss actions and default parties for failure to comply with "discovery requirements." 2021 WL 2559098, at *1.
It is worth remarking that of the three Supreme Court decisions cited in this opinion, the Supreme Court spoke of bad faith in two of them and that not one of the cited cases involved insurance.
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