Legal Opinion

In Re: Amendment to Florida Rule of Civil Procedure 1.280

Supreme Court of Florida

Decided August 26, 2021No. SC21-929Published

1Opinion of the Court

Supreme Court of Florida ____________ No. SC21-929 ____________ IN RE: AMENDMENT TO FLORIDA RULE OF CIVIL PROCEDURE 1.280. August 26, 2021 MUÑIZ, J. Many courts apply the “apex doctrine” to protect high-level corporate officers from the risk of abusive discovery, while still honoring opposing litigants’ right to depose such persons if necessary. 1 Florida’s version of the apex doctrine, developed by the district courts of appeal as a common law gloss on our rules of civil 1. See, e.g., Tierra Blanca Ranch High Country Youth Program v. Gonzalez, 329 F.R.D. 694, 696 (D.N.M. 2019) (the apex…

2Cases cited10 opinions

  1. Williams v. OkenSupreme Court of Florida · 2011
  2. Allstate Ins. Co. v. BoecherSupreme Court of Florida · 1999
  3. State Ex Rel. Ford Motor Co. v. MessinaSupreme Court of Missouri · 2002
  4. Liberty Mutual Insurance v. Superior CourtCalifornia Court of Appeal · 1992
  5. CREST INFINITI, II, LP v. SwintonSupreme Court of Oklahoma · 2007

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