Dodson v. Persell

The controlling question on this appeal is whether the plaintiffs in a personal injury action were entitled to the discovery of surveillance films under Florida Rule of Civil Procedure 1.280. The plaintiffs rely for reversal upon Corack v. Travelers Insurance Company, 347 So.2d 641 (Fla. 4th DCA 1977); and Spencer v. Beverly, 307 So.2d 461 (Fla. 4th DCA 1975).

This court has held that surveillance films may constitute work product and may be excluded from discovery on that basis. See Collier v. McKesson, 121 So.2d 673 (Fla. 3d DCA 1960). We hold that the refusal of the trial court to require…