Florida Contract Law Summary

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In the article, “The Material Difference in Florida Contract Law” by John Crabtree, Mr. Crabtree points out a rather glaring inconsistency regarding the standards of breach of contract cases within the Florida legal system. He goes on to explain that, in all 49 states besides Florida, breach of contract cases have three main requirements; the existence of a valid contract, a breach of that contract, and damages caused by that breach. However, four of Florida’s district courts of appeal have somewhat recently commenced requiring proof of a “material” breach as an additional requirement in these same cases, which is something that sets them apart from the rest of the United States. Not only is this an irregularity when compared with the rest …show more content…

The major fact used to support this thesis is the rationality behind the genesis of this ruling in the case of Abbott Labs v. GE Capital back in 2000. In this case, “the Florida district court injected the materiality requirement without explanation. Moreover, the cases cited by Abbott Labs do not list ‘material breach’ as an element of a breach of contract action” (Crabtree, 2016, p.36). At the same time, many of the Florida cases that have listed “material breach” as an element of breach of contract action can be traced back to the Abbott Labs decision. Crabtree then cites the case of Havens v. Coast Florida, which not only substituted materiality for causation, but also cited the case of Rollins, Inc. v. Butland in support of its decision. This was done even though the case of Rollins, Inc. v. Butland did not include materiality as an element. Though Crabtree’s article is a bit confusing upon first read, its puzzling nature only strengthens his position that the decision and support used to include a material element in these cases

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