Historical source record

Coates v. R.J. Reynolds Tobacco Co., 365 So. 3d 353 (Fla. 2023)

Archived and annotated byTravis Brett CreightonFounder, author, and researcher
Source type
Court decision
Date
January 5, 2023
Issuing body or court
Supreme Court of Florida
Jurisdiction
Florida
Citation
365 So. 3d 353 (Fla. 2023)
Source checked
2026-09-12

Related Florida Hellthcare pages

What it establishes: Coates held that a punitive-damages award in a wrongful-death action must bear a reasonable relationship to the damages proved and the legally cognizable injury suffered by the statutory beneficiaries. The Court held that the decedent’s death itself is not a cognizable injury to the estate under Florida’s Wrongful Death Act.

Why it matters: Section 768.21(8) removes specified damages otherwise recoverable by adult children and parents of adult children in medical-negligence cases. Coates illustrates how removing those beneficiary injuries can also narrow the compensatory reference point used to evaluate punitive damages, even though Martin continues to recognize punitive damages in a wrongful-death action.

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