Ian Hendry, et al. v. Ankinyele Adams (Nos. 3D22-2046 & 3D24-903, Lower Tribunal No. 18-20410)
(a) Facts
The case, Ian Hendry, et al. v. Ankinyele Adams (Nos. 3D22-2046 & 3D24-903, Lower Tribunal No. 18-20410), involves appeals from the Circuit Court for Miami-Dade County, presided over by Judge David C. Miller. The appellants—Ian Hendry, Club Management, LLC, and the Netherland of South Beach Condominium Association, Inc.—challenged an amended final judgment and a subsequent award of attorney’s fees in favor of the appellee, Ankinyele Adams, an African American male and owner of V-Live, a restaurant on South Beach. Adams initiated the lawsuit against the appellants, alleging malicious prosecution, civil conspiracy to commit malicious prosecution, and intentional infliction of emotional distress (IIED) stemming from multiple arrests for alleged noise violations at his establishment. Adams contended during the trial that these arrests were racially motivated.
Procedurally, the appellants filed motions in limine before trial to exclude references to racial discrimination, arguing that Adams had not pleaded such a claim in his fourth amended complaint and lacked supporting evidence. The trial court denied these motions, reasoning that the evidence was relevant to credibility and bias. At trial, Adams presented claims to the jury, including assertions that he was the first Black business owner on South Beach and the only one arrested for noise violations—statements the appellants contested as unsupported and prejudicial. Following a jury verdict in Adams’s favor on all counts except punitive damages, he was awarded $5 million in non-economic damages and $300,000 for legal fees related to his criminal defense (later remitted to $125,000). The appellants’ post-trial motions for a directed verdict, new trial, or remittitur were largely denied, prompting their appeal.
On February 12, 2025, the Third District Court of Appeal reversed the trial court’s amended final judgment (Case 3D22-2046) and the attorney’s fees award (Case 3D24-0903), remanding the primary case for a new trial.
(b) Issues
The central dispute on appeal was whether the trial court abused its discretion by admitting evidence of racial discrimination when Adams had not pleaded it in his operative fourth amended complaint. A secondary issue was whether the attorney’s fees award should stand if the primary judgment was overturned.
(c) Holding
The Third District Court of Appeal held that the trial court abused its discretion in admitting evidence of racial discrimination, as Adams failed to plead this claim in his fourth amended complaint. Consequently, the court reversed the final judgment and remanded the case for a new trial (Case 3D22-2046). The court further held that, due to the reversal of the primary judgment, the attorney’s fees award in favor of Adams (Case 3D24-0903) must also be reversed.
(d) Rationale
The appellate court’s reasoning rested on established Florida precedent governing the pleading requirements for claims involving racial discrimination. The court noted that Adams’s second amended complaint had included a count for “Conspiracy to Violate Civil Rights” under 42 U.S.C. § 1983(3), explicitly alleging racial discrimination, but this count was omitted from the third and fourth amended complaints. Citing cases such as Weaver v. Leon County Classroom Teachers Association (680 So. 2d 478, Fla. 1st DCA 1996) and State v. Burch (545 So. 2d 279, Fla. 4th DCA 1989), the court emphasized that a plaintiff must, at minimum, plead their race and a discriminatory motive to sustain such a claim. Adams’s failure to do so in the operative complaint rendered the introduction of racial discrimination evidence at trial improper.
The court further reasoned that the trial court’s denial of the appellants’ motions in limine and its admission of this evidence constituted an abuse of discretion, as reviewed under Miami-Dade County v. Asad (78 So. 3d 660, Fla. 3d DCA 2012). This error prejudiced the appellants by allowing the jury to consider an unpleaded theory of liability, necessitating a new trial. The reversal of the attorney’s fees award followed logically, as it was contingent on the now-overturned primary judgment.
(e) Comments
This decision underscores the critical importance of precise pleading in civil litigation, particularly when advancing claims as serious as racial discrimination. The appellate court’s strict adherence to procedural rules reflects a commitment to fairness, ensuring that defendants are not blindsided by unpleaded theories at trial
Opinion: