City of Hidalgo, Individually and City of Hidalgo, Texas Municipal Facilities Corporation D/B/A Payne Arena v. Anita Saldana

IN THE SUPREME COURT OF PENNSYLVANIA EASTERN DISTRICT CAROLEEN JAKMIAN, : No. 266 EAL 2024 : Petitioner : : Petition for Allowance of Appeal : from the Order of the v. : Commonwealth Court : : CITY OF PHILADELPHIA AND : SOUTHEASTERN PENNSYLVANIA : TRANSPORTATION AUTHORITY, : : Respondents : ORDER PER CURIAM AND NOW, this 11th day of June, 2025, the Petition for Allowance of Appeal is DENIED. Justice Dougherty files a concurring statement.

In the Court of Appeals Second Appellate District of Texas at Fort Worth No. 02-24-00252-CV JIM BURGESS, Appellant § On Appeal from County Court at Law No. 2 § of Tarrant County (2022-000739-2) V. § June 19, 2025 CITY OF WESTWORTH VILLAGE, Appellee § Opinion by Justice Wallach JUDGMENT This court has considered the record on appeal in this case and holds that there was error in the trial court’s judgment. It is ordered that the judgment of the trial court is reversed and the case is remanded to the trial court for further proceedings consistent with this opinion. It is further ordered that Appellee City of Westworth Village must pay all costs of this appeal, for which let execution issue. SECOND DISTRICT COURT OF APPEALS By _/s/ Mike Wallach___________________ Justice Mike Wallach

THE THIRTEENTH COURT OF APPEALS 13-23-00311-CV Amber Cervantes v. City of Corpus Christi On Appeal from the County Court at Law No. 1 of Nueces County, Texas Trial Court Cause No. 2015CCV-62576-1 JUDGMENT THE THIRTEENTH COURT OF APPEALS, having considered this cause on appeal, concludes that the judgment of the trial court should be affirmed. The Court orders the judgment of the trial court AFFIRMED. Costs of the appeal are adjudged against appellant. We further order this decision certified below for observance. June 18, 2025

Third District Court of Appeal State of Florida Opinion filed August 6, 2025. Not final until disposition of timely filed motion for rehearing. ________________ No. 3D24-0971 Lower Tribunal No. 21-7788-CA-01 ________________ Ramon International Insurance Brokers, Inc., etc., and Iris Arden, Appellants, vs. Chaucer Syndicates Limited, etc., and Anova Marine Insurance Services, LLC, Appellees. An Appeal from a non-final order from the Circuit Court for Miami-Dade County, Lisa S. Walsh, Judge. Fox Rothschild LLP, and Joseph A. DeMaria and Victor Sanabria, for appellants. Colodny Fass, and Maria Elena Abate and Fernando J. Valle (Sunrise), for appellees. Before FERNANDEZ, MILLER, and GOODEN, JJ. PER CURIAM.  Appellants Ramon International Insurance Brokers, Inc. and Iris Arden appeal the trial court’s order on dueling motions to amend for punitive damages. The trial court denied Ramon International’s request, but granted Appellees Chaucer Syndicates Limited’s and Anova Marine Insurance Services, LLC’s request. We affirm the denial of Ramon International’s motion without further discussion. But we reverse the grant of Chaucer Syndicates’ and Anova Marine Insurance’s motion. In their complaint, Anova Marine Insurance and Chaucer Syndicates assert numerous causes of action sounding in both tort and contract. The trial court permitted punitive damages to be pled against Arden in Count V for fraud and against Ramon in Count VI for fraud in the inducement. Yet the Appellees seek the same damages as their contract claims—the difference in premiums collected and wrongly retained. For this reason, we reverse the order allowing amendment for punitive damages. See S. Bell Tel. & Tel. Co. v. Hanft, 436 So. 2d 40, 42 (Fla. 1983) (“In general, punitive damages may not be awarded in cases based upon breach of contract. In order for punitive damages to be recoverable in such a case, the breach of contract must be attended by some additional wrongful conduct amounting to an independent tort.”); Ghodrati v. Miami Paneling Corp., 770 So. 2d 181, 182–83 (Fla. 3d DCA 2000) (“Punitive damages are generally not 2 recoverable for a breach of contract unless it is accompanied by a separate and independent tort claim. Plaintiff argues that because her complaint pled tort claims of fraudulent inducement, deceit and negligent misrepresentation this case falls within the exception and she is entitled to punitive damages. A plaintiff, however, may not recover damages for fraud that duplicate damages awarded for breach of contract.”) (citations omitted); see also Peebles v. Puig, 223 So. 3d 1065, 1069 (Fla. 3d DCA 2017) (“Under such circumstances, Florida does not allow a party damaged by a breach of contract to recover the exact same contract damages via a fraud claim.”); Ginsberg v. Lennar Florida Holdings, Inc., 645 So. 2d 490, 494 (Fla. 3d DCA 1994) (“It is well established that breach of contractual terms may not form the basis for a claim in tort. Where damages sought in tort are the same as those for breach of contract a plaintiff may not circumvent the contractual relationship by bringing an action in tort.”). Reversed, in part; affirmed, in part. 3 Third District Court of Appeal State of Florida Opinion filed August 6, 2025. Not final until disposition of timely filed motion for rehearing. ________________ No. 3D24-0971 Lower Tribunal No. 21-7788-CA-01 ________________ Ramon International Insurance Brokers, Inc., etc., and Iris Arden, Appellants, vs. Chaucer Syndicates Limited, etc., Anova Marine Insurance Services, LLC, Appellees. An Appeal from a non-final order from the Circuit Court for Miami-Dade County, Lisa S. Walsh, Judge. Fox Rothschild LLP, and Joseph A. DeMaria and Victor Sanabria, for appellants. Colodny Fass, and Maria Elena Abate and Fernando J. Valle (Sunrise), for appellees. Before FERNANDEZ, MILLER, and GOODEN, JJ. PER CURIAM.  Appellants Ramon International Insurance Brokers, Inc. and Iris Arden appeal the trial court’s order on dueling motions to amend for punitive damages. The trial court denied Ramon International’s request, but granted Appellees Chaucer Syndicates