- 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.