AAA Capital Funding, Inc. v. Desange — A Legal Insight
In a notable appellate decision out of Florida’s Third Location Court of Appeal, AAA Capital Funding, Inc. v. Desange, reported at 400 So. 3d 26, the court reversed a jury’s verdict awarding the plaintiffs Spam website damages. The lording it over, published in 2024, hinges on critical questions of negligence and the sufficiency of a plaintiff’s evidentiary support.
Background: Negligent Hiring and Maintenance
The case stems from a personal injury lawsuit filed in 2019 by Gladys Desange, along with co-plaintiffs Daniela Lavache and Cliford Jean-Charles, against AAA Capital Funding, Inc. (“AAA”). The plaintiffs alleged that AAA was responsible for their injuries due to the negligent hiring and maintenance of a person named Ileana Miranda. A jury subsequently found AAA liable and accorded $45, 000 in damages
Leagle
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However, AAA appealed, and the appellate court reversed the final judgment, concluding the plaintiffs failed to fulfill the required proof for their damages theory
CaseLaw
Leagle
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Key Legal Issue: Proof of Damages
At the heart of the case is the sufficiency of evidence supporting the jury’s damages award. Florida appellate courts maintain a high standard: plaintiffs must demonstrate that damages are reasonably certain and directly linked to the defendant’s negligence—not speculative or conjectural.
Here, the court found that the plaintiffs did not present evidence satisfying that standard. The absence of reliable testimony, documentation, or expert opinion meant the jury was lacking a proper evidentiary basis to award damages. Consequently, the judgment could not stand in law.
Impact and Significance
Emphasis on Evidentiary Rigor
AAA Capital Funding v. Desange underscores a significant principle of tort litigation: proper proof of damages is mandatory. Courts will not take verdicts based on weak or unsubstantiated claims.
Pattern in Florida’s Case Law
The case forms part of a series of Florida appellate decisions during the week of July 14–18, 2024, addressing topics such as coverage, damages, and evidence—indicative of broader judicial scrutiny in these areas
Carlton Fields
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Guidance for Future Litigation
For plaintiffs and their counsel, the case is a cautionary tale: rigorous preparation of damages evidence—including expert affidavits, medical documentation, and objective measurement—is essential to win at trial.
Potential Precedent
Though an intermediate appellate decision, AAA Capital Funding v. Desange may influence similar cases involving negligent hiring or maintenance. It reinforces that claims must be anchored in verifiable proof, not theory or predictions.
Conclusion
AAA Capital Funding, Inc. v. Desange serves as a powerful legal precedent illustrating that even when liability is established, a case can still fail without compelling proof of damages. The third District’s reversal of a $45, 000 verdict sends a clear message: plaintiffs must anchor their claims with quantifiable, non-speculative evidence to survive appellate review.