Historical source record

Martin v. United Security Services, Inc., 314 So. 2d 765 (Fla. 1975)

The decision explaining the 1972 Act as a consolidation and substitution of death-causing remedies.

Archived and annotated byTravis Brett CreightonFounder and principal researcher, Florida Hellthcare
Source type
Court decision
Date
April 23, 1975
Issuing body or court
Supreme Court of Florida
Citation
314 So. 2d 765 (Fla. 1975)
Source checked
2026-09-11

What it establishes: Martin upheld the 1972 Act’s consolidation of survival and wrongful-death actions and described the decedent’s pain-and-suffering claim as eliminated when the injury caused death, with survivor pain and suffering substituted.

Why it matters: The decision is the bridge between the 1972 statutory text and the later question whether the 1990 medical-negligence exclusion withdrew part of the substituted remedy from specified survivors.

Return to the Historical Source Archive