APPEALS--DISMISSAL OF COMPLAINT--FRAUD ON COURT--STANDARD OF REVIEW. In reviewing a trial court's dismissal of an action for fraud on the court, the district court erred by applying a "more stringent" abuse of discretion standard and reversing the sanction. When reviewing a trial court's dismissal of an action for fraud on the court, a district court should review the trial court's "factual findings for competent, substantial evidence; its legal conclusions de novo; and its choice of sanction for abuse of discretion." "[N]othing requires the appellate court to hold the lower court to a more stringent' reasonableness standard once it has determined that the court had discretion to act."
VIEW OPINION

WORKERS' COMPENSATION--COMPENSABLE ACCIDENTS--SHOOTINGS. When a third-party tortfeasor assaults an employee who is in the course and scope of employment, the resulting injuries can be compensable under workers' compensation law so long as the claimant can meet its burden of establishing work-relatedness. To determine work-relatedness, the necessary inquiry is whether a work risk somehow caused or contributed to the injury. In determining that a claimant who was shot while walking between facilities at work was not entitled to workers' compensation benefits for his injuries because his "walking" in the performance of his work did not cause him to suffer injuries from a shooting, the district court improperly focused on claimant's isolated task rather than on claimant's overall work duties and work environment.
VIEW OPINION

DISSOLUTION OF MARRIAGE--EQUITABLE DISTRIBUTION--PREJUDGMENT INTEREST. The Court held that a trial court has discretionary authority to award prejudgment interest in order to achieve equity in distributing marital property under section 61.075. Section 61.075 expressly authorizes those remedies "available to a court to do equity between the parties," and prejudgment interest can be fairly described as an equitable remedy in this context. Consistent with its analysis, the Court stressed that "a party in such proceedings is not automatically entitled to prejudgment interest." There must be some facts or circumstances justifying the award, "and even where a sufficient basis exists, the trial court retains discretion in determining whether this particular remedy would be a fitting tool to do equity between the parties.' "
VIEW OPINION