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reformation-fl

oid int64	cid int64	name string	court string	year int64	cites int64	instrument string	outcome string	regime string	errors string	n_reform_sents int64	key_sentence string	statement string
1,088,301	1,088,301	Niagara Fire Insurance Co. v. Allied Electrical Co.	fladistctapp	1,975	15	insurance	sought	equitable	mutual_mistake	8	Niagara contends that there was not sufficient legal basis to reform the contract of insurance and delete the "water-borne" exclusion because prior to, and at the time of the insurance contract, there was no meeting of the minds or communication between Allied and Niagara on the portion of the contract that is sought t...	Niagara Fire Insurance Co. v. Allied Electrical Co. (1975) litigated reformation of an insurance policy in the Florida appellate courts; reformation was sought; the decision does not state the outcome in a sentence naming the remedy. Alleged error: mutual_mistake. Reformation regime in force: equitable.
1,088,416	1,088,416	Criterion Insurance Company v. Gutierrez	fladistctapp	1,975	4	insurance	uncertain	equitable	unspecified	1	The order awarded $1,500 to appellee, plaintiff in the trial court, for her attorney's services in connection with obtaining certain personal injury protection benefits (PIP) and other benefits pursuant to an insurance policy between appellant insurance company and appellee governed by the Florida Automobile Reparation...	Criterion Insurance Company v. Gutierrez (1975) litigated reformation of an insurance policy in the Florida appellate courts; the outcome could not be classified. Alleged error: unspecified. Reformation regime in force: equitable.
1,088,616	1,088,616	Canal Ins. Co. v. Giesenschlag	fladistctapp	1,984	4	insurance	uncertain	equitable	unspecified	2	The circuit court entered summary judgment for appellees and reformed the insurance policy to provide coverage in the amounts required by the ordinance.	Canal Ins. Co. v. Giesenschlag (1984) litigated reformation of an insurance policy in the Florida appellate courts; the outcome could not be classified. Alleged error: unspecified. Reformation regime in force: equitable.
1,089,556	1,089,556	Milford v. Metropolitan Dade County	fladistctapp	1,983	11	insurance	authority	equitable	unspecified	3	NOTES [1] All references to Milford are intended to include her insurer, G.E.I.C.O. [2] The section provides: "RIGHT TO CONTRIBUTION "(d) A tortfeasor who enters into a settlement with a claimant is not entitled to recover contribution from another tortfeasor whose liability for the injury or wrongful death ...	Milford v. Metropolitan Dade County (1983) litigated reformation of an insurance policy in the Florida appellate courts; the opinion discusses reformation authority rather than holding. Alleged error: unspecified. Reformation regime in force: equitable.
1,092,179	1,092,179	Metropolitan Dade County v. RESOURCES RECOVERY	fladistctapp	1,985	6	contract	authority	equitable	unspecified	1	In their demand, they sought a declaration that the County had not used its "best efforts" to arrange to complete the purchase of the electrical generating facility through the sale of bonds or otherwise (as required by the Assumption Agreement, see n. 1, supra, as reformed by the Revised Award) and the further relief ...	Metropolitan Dade County v. RESOURCES RECOVERY (1985) litigated reformation of a contract in the Florida appellate courts; the opinion discusses reformation authority rather than holding. Alleged error: unspecified. Reformation regime in force: equitable.
1,092,419	1,092,419	Schechtman v. Grobbel	fladistctapp	1,969	22	contract	uncertain	equitable	unspecified	1	Indeed, it amounts either to a reformation of the contract so as to change the contractual rights of the mortgagees, or to impairing their right to enforce those which clearly appear. [5] We conclude therefore that the trial judge was correct in denying foreclosure.	Schechtman v. Grobbel (1969) litigated reformation of a contract in the Florida appellate courts; the outcome could not be classified. Alleged error: unspecified. Reformation regime in force: equitable.
1,092,669	1,092,669	In Re Estate of Rice	fladistctapp	1,981	17	will	uncertain	pre-statute	unspecified	4	After receiving testimony from the scrivener of the decedent's will and a trust officer concerning the administration of the marital and residuary trusts, the probate court granted the co-personal representatives' petition for construction of the will.	In Re Estate of Rice (1981) litigated reformation of a will in the Florida appellate courts; the outcome could not be classified. Alleged error: unspecified. Reformation regime in force: pre-statute.
1,093,010	1,093,010	State v. Graham	fladistctapp	1,970	12	deed	authority	equitable	unspecified	1	Prior v. Davis, 1909, 58 Fla. 510 , 50 So. 535 (evidence to reform a written deed so as to conform to an alleged parol agreement must be "full, clear, and convincing.") Additionally, Fla. Stat. 387.10 (1967) F.S.A. provides that in any proceeding for a temporary injunction without bond against an industrial, manufactur...	State v. Graham (1970) litigated reformation of a deed in the Florida appellate courts; the opinion discusses reformation authority rather than holding. Alleged error: unspecified. Reformation regime in force: equitable.
1,093,067	1,093,067	Haynes v. Carbonell	fladistctapp	1,988	11	deed	uncertain	equitable	scriveners_error	1	If, as Strand admits, *749 the land conveyed to Haynes in 1967 is the same parcel Strand received by deed in 1953 which extended to the Gulf of Mexico then the existence of the 50-foot "no man's land" can be explained as a mistake by the surveyor for the 1953 deed in measuring the site from the point of beginning t...	Haynes v. Carbonell (1988) litigated reformation of a deed in the Florida appellate courts; the outcome could not be classified. Alleged error: scriveners_error. Reformation regime in force: equitable.
1,093,584	1,093,584	Allstate Insurance Company v. Vanater	fla	1,974	37	insurance	rule_stated	equitable	mutual_mistake	12	We accordingly hold that in suits for the reformation of a written contract the burden of proof which the plaintiff must sustain is that of clear and convincing evidence; the plaintiff need not prove his cause beyond a reasonable doubt in such cases.	Allstate Insurance Company v. Vanater (1974) litigated reformation of an insurance policy in the Florida appellate courts; the opinion states the reformation rule without holding on it. Alleged error: mutual_mistake. Reformation regime in force: equitable.
1,094,177	1,094,177	City of Mascotte v. FLORIDA MUN. LIABILITY SELF INSURERS PROGRAM	fladistctapp	1,983	13	contract	sought	equitable	unspecified	2	The supplemental relief sought is also on the contract, a reformation of it.	City of Mascotte v. FLORIDA MUN. LIABILITY SELF INSURERS PROGRAM (1983) litigated reformation of a contract in the Florida appellate courts; reformation was sought; the decision does not state the outcome in a sentence naming the remedy. Alleged error: unspecified. Reformation regime in force: equitable.
1,094,535	1,094,535	Rules Regulating the Florida Bar	fla	1,986	50	insurance	uncertain	equitable	unspecified	1	Established, written policies in this respect can enhance the credibility of such assurances. 4-6.4 Law reform activities affecting client interests.	Rules Regulating the Florida Bar (1986) litigated reformation of an insurance policy in the Florida appellate courts; the outcome could not be classified. Alleged error: unspecified. Reformation regime in force: equitable.
1,094,982	1,094,982	Rivers v. Lozeau	fladistctapp	1,989	7	deed	uncertain	equitable	unspecified	2	To the extent that Rizzo's deed conveyed legal title to land Rizzo did not intend to convey, Rizzo's remedy would have been to have brought a reformation suit in equity to have his deed reformed to describe the correct parcel by a correct description.	Rivers v. Lozeau (1989) litigated reformation of a deed in the Florida appellate courts; the outcome could not be classified. Alleged error: unspecified. Reformation regime in force: equitable.
1,097,312	1,097,312	Williams v. Leatherby Ins. Co.	fladistctapp	1,976	7	insurance	rule_stated	equitable	unspecified	2	Defendant Leatherby Insurance Company filed an answer to the complaint denying the plaintiff's allegations and stating that the plaintiff is barred from recovering nofault benefits under the policy of his sister, Betty Jean, since plaintiff himself was the owner of a motor vehicle with respect to which security is requ...	Williams v. Leatherby Ins. Co. (1976) litigated reformation of an insurance policy in the Florida appellate courts; the opinion states the reformation rule without holding on it. Alleged error: unspecified. Reformation regime in force: equitable.
1,097,412	1,097,412	Nussey v. Caufield	fladistctapp	1,962	8	deed	uncertain	equitable	mutual_mistake	1	As in cases where reformation of an instrument is sought on the ground of mutual mistake of fact, a party seeking rescission and cancellation of an instrument on such a ground has the burden to present clear and convincing evidence that a mistake of fact was made in the transaction sought to be altered or abrogated.	Nussey v. Caufield (1962) litigated reformation of a deed in the Florida appellate courts; the outcome could not be classified. Alleged error: mutual_mistake. Reformation regime in force: equitable.
1,097,533	1,097,533	American Fire & Indem. Corp. v. STATE FARM AUTO.	fladistctapp	1,986	7	contract	uncertain	equitable	mutual_mistake	1	A contract cannot be reformed in the absence of mutual mistake.	American Fire & Indem. Corp. v. STATE FARM AUTO. (1986) litigated reformation of a contract in the Florida appellate courts; the outcome could not be classified. Alleged error: mutual_mistake. Reformation regime in force: equitable.
1,097,827	1,097,827	Clearwater Key Ass'n-South Beach, Inc. v. Thacker	fladistctapp	1,983	9	contract	rule_stated	equitable	unspecified	3	Generally speaking, a court of equity has the power to reform an instrument to correct a draftsman's mistake.	Clearwater Key Ass'n-South Beach, Inc. v. Thacker (1983) litigated reformation of a contract in the Florida appellate courts; the opinion states the reformation rule without holding on it. Alleged error: unspecified. Reformation regime in force: equitable.
1,098,474	1,098,474	Seijas v. Seijas	fladistctapp	1,990	6	deed	uncertain	equitable	unspecified	1	The final judgment ordered that the deed of the marital home, be reformed to reflect title in the names of the husband and wife, jointly, while finding that a quit-claim deed which the wife had executed in favor of the husband, prior to the dissolution action, was null and void because the transfer had been made under ...	Seijas v. Seijas (1990) litigated reformation of a deed in the Florida appellate courts; the outcome could not be classified. Alleged error: unspecified. Reformation regime in force: equitable.
1,098,650	1,098,650	Boston Old Colony Insurance Company v. Popple	fladistctapp	1,974	5	insurance	sought	equitable	mutual_mistake	6	There our sister court held reformation of an insurance policy would not be ordered because it was manifest that at the time the policy was issued neither party contemplated the type coverage sought in the suit for reformation.	Boston Old Colony Insurance Company v. Popple (1974) litigated reformation of an insurance policy in the Florida appellate courts; reformation was sought; the decision does not state the outcome in a sentence naming the remedy. Alleged error: mutual_mistake. Reformation regime in force: equitable.
1,098,766	1,098,766	Iglehart v. Phillips	fla	1,980	49	trust	uncertain	pre-statute	unilateral_mistake	1	We disagree with the conclusions reached by the United States District Court that the unreasonable restraint contained in the repurchase covenant was a unilateral mistake of law by the grantor.	Iglehart v. Phillips (1980) litigated reformation of a trust in the Florida appellate courts; the outcome could not be classified. Alleged error: unilateral_mistake. Reformation regime in force: pre-statute.
1,099,603	1,099,603	Connelly v. Smith	fladistctapp	1,957	15	deed	uncertain	equitable	unspecified	2	The grantee Smith sued the executor of the estate of the then deceased grantor, seeking a decree quieting title to the property and in the alternative to reform the deed to show a section, township and range.	Connelly v. Smith (1957) litigated reformation of a deed in the Florida appellate courts; the outcome could not be classified. Alleged error: unspecified. Reformation regime in force: equitable.
1,100,012	1,100,012	State Farm Mut. Auto. Ins. Co. v. Chapman	fladistctapp	1,982	9	insurance	uncertain	equitable	unspecified	2	Any insurance policy purporting to provide security in accordance with Florida's Automobile Reparations Reform Act is to be enforced as if it were in compliance with the act, irrespective of its actual terms.	State Farm Mut. Auto. Ins. Co. v. Chapman (1982) litigated reformation of an insurance policy in the Florida appellate courts; the outcome could not be classified. Alleged error: unspecified. Reformation regime in force: equitable.
1,100,186	1,100,186	Canal Ins. Co. v. Hartford Ins. Co.	fladistctapp	1,982	16	insurance	uncertain	equitable	mutual_mistake	6	The trial court was able to make that determination by reforming the insurance policy to reflect the alleged intent of the parties to include Americus as a named insured.	Canal Ins. Co. v. Hartford Ins. Co. (1982) litigated reformation of an insurance policy in the Florida appellate courts; the outcome could not be classified. Alleged error: mutual_mistake. Reformation regime in force: equitable.
1,100,286	1,100,286	General Development Corporation v. Kirk	fladistctapp	1,971	27	deed	rule_stated	equitable	mutual_mistake	3	General Development sought to reform the deed given by the Trustees to the Conways.	General Development Corporation v. Kirk (1971) litigated reformation of a deed in the Florida appellate courts; the opinion states the reformation rule without holding on it. Alleged error: mutual_mistake. Reformation regime in force: equitable.
1,100,799	1,100,799	Providence Square Ass'n v. Biancardi	fla	1,987	54	deed	uncertain	equitable	scriveners_error,mutual_mistake	11	A court of equity has the power to reform a written instrument where, due to a mutual mistake, the instrument as drawn does not accurately express the true intention or agreement of the parties to the instrument.	Providence Square Ass'n v. Biancardi (1987) litigated reformation of a deed in the Florida appellate courts; the outcome could not be classified. Alleged error: scriveners_error, mutual_mistake. Reformation regime in force: equitable.
1,101,137	1,101,137	Gassner v. Bechtel Const.	fladistctapp	1,997	7	contract	uncertain	equitable	scriveners_error	1	The judge of compensation claims received testimony on this point concerning an alleged scrivener's error and a corrective amendment to the original collective bargaining agreement purportedly in force at the time of the hearing.	Gassner v. Bechtel Const. (1997) litigated reformation of a contract in the Florida appellate courts; the outcome could not be classified. Alleged error: scriveners_error. Reformation regime in force: equitable.
1,101,319	1,101,319	FLORIDA INS. GUARANTY ASSOCIATION, INC. v. Love	fladistctapp	1,999	6	contract	authority	equitable	unilateral_mistake	2	We realize that in many respects this case is similar to BMW of North America, Inc. v. Krathen, 471 So.2d 585 (Fla. 4th DCA 1985), where the court denied rescission, finding that a unilateral mistake in a settlement agreement constituted an inexcusable lack of due care.	FLORIDA INS. GUARANTY ASSOCIATION, INC. v. Love (1999) litigated reformation of a contract in the Florida appellate courts; the opinion discusses reformation authority rather than holding. Alleged error: unilateral_mistake. Reformation regime in force: equitable.
1,101,387	1,101,387	In Re Estate of Huls	fladistctapp	1,999	3	trust	uncertain	pre-statute	scriveners_error	3	In pertinent part, the order in effect reforms or revokes the decedent's trust by replacing it with a new trust, with the widow as settlor and with otherwise slightly different terms than those set forth in the decedent's trust instrument.	In Re Estate of Huls (1999) litigated reformation of a trust in the Florida appellate courts; the outcome could not be classified. Alleged error: scriveners_error. Reformation regime in force: pre-statute.
1,101,391	1,101,391	Lucas v. Barnett Bank of Lee County	fladistctapp	1,999	7	contract	authority	equitable	unspecified	2	Yost v. Congress International Development Corp., 383 So.2d 732, 732 (Fla. 3d DCA 1980) (holding that prevailing party on appeal entitled to immediate award of appellate costs without stay of execution). *407 Barnett Bank does not dispute the general principle, but contends that as a practical matter the Lucases did ...	Lucas v. Barnett Bank of Lee County (1999) litigated reformation of a contract in the Florida appellate courts; the opinion discusses reformation authority rather than holding. Alleged error: unspecified. Reformation regime in force: equitable.
1,101,813	1,101,813	Industrial Fire & Cas. Ins. Co. v. Jones	fladistctapp	1,978	5	insurance	uncertain	equitable	unspecified	1	Accordingly, the plaintiff urges that Industrial's policy does not conform to statutory requirements because the definition given in the policy for "named insured" varies from the definition provided by the Florida Automobile Reparation Reform Act, Section 627.730, et seq., Florida Statutes (1977), where Section 627.73...	Industrial Fire & Cas. Ins. Co. v. Jones (1978) litigated reformation of an insurance policy in the Florida appellate courts; the outcome could not be classified. Alleged error: unspecified. Reformation regime in force: equitable.
1,101,938	1,101,938	Matthews v. State	fla	1,978	4	will	authority	pre-statute	unspecified	1	NOTES [1] As pointed out in the opinion of the district court there was conflicting evidence as to whether the precise word "assassinate" was used by the demonstrators, but the jury's verdict binds a reviewing court to the "assassination" version of the chant urged by the State. [2] § 836.05, Fla. Stat. (1973), sta...	Matthews v. State (1978) litigated reformation of a will in the Florida appellate courts; the opinion discusses reformation authority rather than holding. Alleged error: unspecified. Reformation regime in force: pre-statute.
1,102,214	1,102,214	Lakes of the Meadow v. ARVIDA/JMB	fladistctapp	1,998	6	contract	uncertain	equitable	unilateral_mistake	1	"Florida case law supports the proposition that relief will be granted for unilateral mistake where the mistake goes to the substance of the agreement, is not the result of a lack of due care, and where the other party has not relied upon the mistake to his detriment.	Lakes of the Meadow v. ARVIDA/JMB (1998) litigated reformation of a contract in the Florida appellate courts; the outcome could not be classified. Alleged error: unilateral_mistake. Reformation regime in force: equitable.
1,102,495	1,102,495	Burleson v. Brogdon	fladistctapp	1,978	6	deed	rule_stated	equitable	unspecified	10	The general rule is that a court of equity will not undertake to reform an instrument which is merely voluntary and based upon no consideration. 66 Am.Jur.2d, Reformation of Instruments, § 42 (1973).	Burleson v. Brogdon (1978) litigated reformation of a deed in the Florida appellate courts; the opinion states the reformation rule without holding on it. Alleged error: unspecified. Reformation regime in force: equitable.
1,102,546	1,102,546	Napoli v. Liberty Mut. Ins. Co.	fladistctapp	1,978	4	insurance	uncertain	equitable	unspecified	1	While the testimony of the parents and the insurance company's endorsement do not conclusively prove Jack Napoli, Jr. was *879 a named insured for death benefits coverage this evidence is sufficient prima facie to support the allegations in the count charging reformation of contract.	Napoli v. Liberty Mut. Ins. Co. (1978) litigated reformation of an insurance policy in the Florida appellate courts; the outcome could not be classified. Alleged error: unspecified. Reformation regime in force: equitable.
1,102,872	1,102,872	Collier v. Brooks	fladistctapp	1,994	18	deed	authority	equitable	unspecified	1	And in Canell v. Arcola Housing Corp., 65 So.2d 849, 851 (Fla. 1953), which involved an oral promise to create an casement that the court found "is clearly within the terms of the statute of frauds and thus cannot be enforced directly or indirectly" and "would amount to an unauthorized reformation of the description in...	Collier v. Brooks (1994) litigated reformation of a deed in the Florida appellate courts; the opinion discusses reformation authority rather than holding. Alleged error: unspecified. Reformation regime in force: equitable.
1,103,097	1,103,097	Lopez v. Midwest Mutual Insurance Company	fladistctapp	1,969	14	contract	uncertain	equitable	unspecified	1	The court finds, in the absence of any ambiguities or other insufficiency that the minor Plaintiff is bound by the terms of the executed application contract and there has been no sufficient allegation or proof of any legal grounds for reforming this contract.	Lopez v. Midwest Mutual Insurance Company (1969) litigated reformation of a contract in the Florida appellate courts; the outcome could not be classified. Alleged error: unspecified. Reformation regime in force: equitable.
1,103,755	1,103,755	Chase Federal Sav. and Loan Ass'n v. Schreiber	fla	1,985	28	deed	authority	equitable	unspecified	2	Budd v. Long, 13 Fla. 288 (1869). [13] Similarly in Tampa Northern R. Co. v. City of Tampa, 104 Fla. 481 , 140 So. 311 (1932), the grantee was held entitled to reformation of the deed where the conveyance was made in exchange for a promise to develop the land and improvements were constructed. [14] See also Harknes...	Chase Federal Sav. and Loan Ass'n v. Schreiber (1985) litigated reformation of a deed in the Florida appellate courts; the opinion discusses reformation authority rather than holding. Alleged error: unspecified. Reformation regime in force: equitable.
1,105,836	1,105,836	Daniel v. FLORIDA RESIDENTIAL PROPERTY	fladistctapp	1,998	8	insurance	rule_stated	equitable	mutual_mistake	2	Failure of a policy to express the intended contract of the parties must be occasioned by a mutual mistake, and a mistake on one side is no ground for reformation of a policy.	Daniel v. FLORIDA RESIDENTIAL PROPERTY (1998) litigated reformation of an insurance policy in the Florida appellate courts; the opinion states the reformation rule without holding on it. Alleged error: mutual_mistake. Reformation regime in force: equitable.
1,106,739	1,106,739	Prygrocki v. Industrial Fire & Cas. Ins. Co.	fladistctapp	1,981	10	insurance	uncertain	equitable	unspecified	1	Paraphrasing the language of the policy, it obligated the insurer to pay, in accordance with the Florida Automobile Reparations Reform Act, as amended, to any person while a pedestrian, through being struck by the insured motor vehicle, certain damages incurred as a result of bodily injury caused by accident arising ou...	Prygrocki v. Industrial Fire & Cas. Ins. Co. (1981) litigated reformation of an insurance policy in the Florida appellate courts; the outcome could not be classified. Alleged error: unspecified. Reformation regime in force: equitable.
1,106,792	1,106,792	Bridges v. Thomas	fladistctapp	1,960	4	deed	uncertain	equitable	unspecified	1	The appellant, as plaintiff in the lower court, filed an action to have a deed and purchase money mortgage between her and the appellee-defendants reformed so as to reduce the quantity of land that plaintiff intended to convey to defendants.	Bridges v. Thomas (1960) litigated reformation of a deed in the Florida appellate courts; the outcome could not be classified. Alleged error: unspecified. Reformation regime in force: equitable.
1,106,803	1,106,803	Old Colony Insurance Co. v. Trapani	fladistctapp	1,960	16	insurance	granted	equitable	mutual_mistake	10	After trial before the chancellor, final judgment was entered granting reformation of the insurance policy and awarding plaintiff damages for the previously awarded judgment and attorney's fees plus interest thereon.	Old Colony Insurance Co. v. Trapani (1960) litigated reformation of an insurance policy in the Florida appellate courts; the court granted reformation. Alleged error: mutual_mistake. Reformation regime in force: equitable.
1,107,826	1,107,826	Rosique v. Windley Cove, Ltd.	fladistctapp	1,989	9	contract	uncertain	equitable	mutual_mistake	2	Javier Rosique appeals from a final judgment of the trial court granting rescission of a real estate contract, subsequent to closing, upon a finding of mutual mistake.	Rosique v. Windley Cove, Ltd. (1989) litigated reformation of a contract in the Florida appellate courts; the outcome could not be classified. Alleged error: mutual_mistake. Reformation regime in force: equitable.
1,109,440	1,109,440	Hutchens v. MAXICENTERS, USA	fladistctapp	1,989	4	contract	uncertain	equitable	unspecified	1	All actions for more specific relief, such as, cases involving dissolutions of marriage, custody, guardianships, dissolutions of partnership, accounting, mortgage foreclosure, partition, subrogation, specific performance of contracts, the adjudication of equitable rights of beneficiaries under express trusts, the estab...	Hutchens v. MAXICENTERS, USA (1989) litigated reformation of a contract in the Florida appellate courts; the outcome could not be classified. Alleged error: unspecified. Reformation regime in force: equitable.
1,109,453	1,109,453	Nagashima v. Busck	fladistctapp	1,989	4	contract	authority	equitable	unspecified	2	NOTES [1] The buyer seeks a reduction of the contract price to reflect the value of the building through reformation of the purchase money note. [2] This court in Zuckerman-Vernon Corp. v. Rosen, 361 So.2d 804 (Fla. 4th DCA 1978), permitted recovery for fraud against a real estate broker who misrepresented the stat...	Nagashima v. Busck (1989) litigated reformation of a contract in the Florida appellate courts; the opinion discusses reformation authority rather than holding. Alleged error: unspecified. Reformation regime in force: equitable.
1,109,495	1,109,495	Traveler's Indem. v. Duffy's Tavern	fladistctapp	1,989	8	insurance	uncertain	equitable	unspecified	1	After Duffy's submitted a claim for loss under the policy, Travelers refused to pay and filed suit against Duffy's for rescission, declaratory relief and reformation of the insurance contract.	Traveler's Indem. v. Duffy's Tavern (1989) litigated reformation of an insurance policy in the Florida appellate courts; the outcome could not be classified. Alleged error: unspecified. Reformation regime in force: equitable.
1,109,921	1,109,921	Betz v. Bank of Miami Beach	fla	1,957	22	trust	uncertain	pre-statute	unspecified	1	We believe this rule will cause less harm to commerce and result in less litigation than if we adopted the opposite view. *895 While it cannot assist Betz in his dilemma, it would appear to us that one who claims his signature on a negotiable instrument was intended by the parties to have been placed thereon in a dif...	Betz v. Bank of Miami Beach (1957) litigated reformation of a trust in the Florida appellate courts; the outcome could not be classified. Alleged error: unspecified. Reformation regime in force: pre-statute.
1,110,257	1,110,257	Plumpton v. CONTINNENTAL ACREAGE DEVELOPMENT CO., INC.	fladistctapp	2,002	12	contract	uncertain	equitable	unilateral_mistake	1	Count III involves the Beard contract. [3] Also, as the trial court correctly noted, the parol evidence proffered in this case was inadmissible because it constituted a claim of unilateral mistake.	Plumpton v. CONTINNENTAL ACREAGE DEVELOPMENT CO., INC. (2002) litigated reformation of a contract in the Florida appellate courts; the outcome could not be classified. Alleged error: unilateral_mistake. Reformation regime in force: equitable.
1,110,631	1,110,631	Baker v. State	fladistctapp	2,006	1	deed	uncertain	equitable	scriveners_error	1	Appellee acknowledges, and we agree, that the case should be remanded to correct this scrivener's error in the judgment to reflect that the jury found appellant guilty of burglary of a conveyance.	Baker v. State (2006) litigated reformation of a deed in the Florida appellate courts; the outcome could not be classified. Alleged error: scriveners_error. Reformation regime in force: equitable.
1,112,202	1,112,202	In Re Lomineck's Estate	fladistctapp	1,963	5	will	uncertain	pre-statute	unspecified	4	Pinkston, a person who was the scrivener of the will, who signed testatrix' name thereto, and who was also a subscribing and attesting witness, as hereinafter more fully discussed, made proof of the will in form agreeable to law.	In Re Lomineck's Estate (1963) litigated reformation of a will in the Florida appellate courts; the outcome could not be classified. Alleged error: unspecified. Reformation regime in force: pre-statute.
1,112,871	1,112,871	Reid v. Allstate Ins. Co.	fladistctapp	1,977	7	insurance	uncertain	equitable	unspecified	1	Although it is certainly within the power of the Legislature to prohibit all family-household exclusions in automobile liability insurance policies, we hold that it did not do so by its enactment of the Florida Automobile Reparations Reform Act.	Reid v. Allstate Ins. Co. (1977) litigated reformation of an insurance policy in the Florida appellate courts; the outcome could not be classified. Alleged error: unspecified. Reformation regime in force: equitable.
1,113,114	1,113,114	Holley v. May	fla	1,954	25	deed	rule_stated	equitable	omitted_provision,mutual_mistake	8	That such was not the case is shown affirmatively by the pleading and consequently the issue is governed by the rule that if the mistake of the parties in the conveying of property is in the identity of the property to be conveyed there can be no reformation of the instrument because there has been no initial meeting o...	Holley v. May (1954) litigated reformation of a deed in the Florida appellate courts; the opinion states the reformation rule without holding on it. Alleged error: omitted_provision, mutual_mistake. Reformation regime in force: equitable.
1,118,415	1,118,415	Spear v. MacDonald	fla	1,953	20	deed	sought	equitable	unspecified	5	Petitioners, plaintiffs below, petition for certiorari to review an interlocutory order of the lower court dismissing a complaint for reformation of three deeds and a mortgage.	Spear v. MacDonald (1953) litigated reformation of a deed in the Florida appellate courts; reformation was sought; the decision does not state the outcome in a sentence naming the remedy. Alleged error: unspecified. Reformation regime in force: equitable.
1,126,007	1,126,007	Fleeman v. Case	fla	1,976	75	contract	authority	equitable	unspecified	1	In Plaza Del Prado Condominium Association v. Del Prado Corporation the lessee brought a complaint for reformation of contract and declaratory relief from their lease.	Fleeman v. Case (1976) litigated reformation of a contract in the Florida appellate courts; the opinion discusses reformation authority rather than holding. Alleged error: unspecified. Reformation regime in force: equitable.
1,127,696	1,127,696	Thompson v. Gross	fladistctapp	1,977	4	contract	uncertain	equitable	unspecified	2	This appeal is taken from a final judgment rendered in favor of appellees/defendants and against appellants/plaintiffs in a suit filed by the latter seeking the reformation of a note and mortgage to conform with the provisions of a prior preliminary deposit receipt.	Thompson v. Gross (1977) litigated reformation of a contract in the Florida appellate courts; the outcome could not be classified. Alleged error: unspecified. Reformation regime in force: equitable.
1,127,766	1,127,766	Arcamonte v. Springfield Life Ins. Co.	fladistctapp	1,977	2	insurance	sought	equitable	unspecified	5	"However, and in the event that this Court lacks the power to decide the issues framed by the complaint and answer as regards rescission and reformation, then and in that event, this Court finds as a matter of law that there are no issues of material fact to submit to a jury and hereby directs a verdict in favor of the...	Arcamonte v. Springfield Life Ins. Co. (1977) litigated reformation of an insurance policy in the Florida appellate courts; reformation was sought; the decision does not state the outcome in a sentence naming the remedy. Alleged error: unspecified. Reformation regime in force: equitable.
1,128,316	1,128,316	State v. TMB	fla	1,998	0	insurance	uncertain	equitable	unspecified	1	Public policy, in addition to our rules of appellate procedure, requires that juvenile defendants preserve issues for appellate review in the manner contemplated under the Criminal Reform Act.	State v. TMB (1998) litigated reformation of an insurance policy in the Florida appellate courts; the outcome could not be classified. Alleged error: unspecified. Reformation regime in force: equitable.
1,131,577	1,131,577	Allen v. Berry	fladistctapp	2,000	4	contract	uncertain	equitable	unspecified	1	The Allens appeal from a final judgment granting Berry's request for ejectment and denying Allens' counterclaim for breach of contract, specific performance, reformation and declaratory judgment.	Allen v. Berry (2000) litigated reformation of a contract in the Florida appellate courts; the outcome could not be classified. Alleged error: unspecified. Reformation regime in force: equitable.
1,133,801	1,133,801	Fabing v. Eaton	fladistctapp	2,006	6	contract	sought	equitable	mutual_mistake	5	When Fabing learned of these problems with the appraisal, he sought rescission or reformation of the mediation agreement.	Fabing v. Eaton (2006) litigated reformation of a contract in the Florida appellate courts; reformation was sought; the decision does not state the outcome in a sentence naming the remedy. Alleged error: mutual_mistake. Reformation regime in force: equitable.
1,134,055	1,134,055	Forsythe v. Spielberger	fla	1,956	6	trust	sought	pre-statute	unspecified	2	We have examined the authorities relied on by petitioners and they appear to deal with the question of reformation of an instrument for mistake in contents.	Forsythe v. Spielberger (1956) litigated reformation of a trust in the Florida appellate courts; reformation was sought; the decision does not state the outcome in a sentence naming the remedy. Alleged error: unspecified. Reformation regime in force: pre-statute.
1,135,593	1,135,593	Sponga v. Warro	fladistctapp	1,997	6	contract	uncertain	equitable	unilateral_mistake	3	This is rather a case where one party entered into a mediation settlement agreement based on a unilateral mistake.	Sponga v. Warro (1997) litigated reformation of a contract in the Florida appellate courts; the outcome could not be classified. Alleged error: unilateral_mistake. Reformation regime in force: equitable.
1,135,632	1,135,632	Boulton Agency v. Phoenix Worldwide	fladistctapp	1,997	9	insurance	uncertain	equitable	unspecified	1	Phoenix filed suit against Travelers for breach of contract and reformation, against Travelers and Boulton for negligence for failure to adequate insure Phoenix's non-owned vehicles (including their equipment), and for negligence for failure to adequately insure Phoenix's plant inventory, equipment and contents.	Boulton Agency v. Phoenix Worldwide (1997) litigated reformation of an insurance policy in the Florida appellate courts; the outcome could not be classified. Alleged error: unspecified. Reformation regime in force: equitable.
1,135,723	1,135,723	Spano v. Spano	fladistctapp	1,997	4	contract	authority	equitable	unspecified	2	Flanders v. Flanders, 516 So.2d 1090, 1091 (Fla. 5th DCA 1987) ("In the absence of facts supporting a reformation in equity, courts have no authority to modify a property settlement agreement.");	Spano v. Spano (1997) litigated reformation of a contract in the Florida appellate courts; the opinion discusses reformation authority rather than holding. Alleged error: unspecified. Reformation regime in force: equitable.
1,136,546	1,136,546	Estate of Brock	fladistctapp	1,996	13	will	uncertain	pre-statute	scriveners_error	1	Due to a drafting error in the final documents prepared by Mr. Isler, the names of the personal representatives and the relationships of some of the beneficiaries had to be corrected. [3] Subsequently, Mr. Isler learned that Dr. Brock's failure to return to his office to sign the corrected documents was due to Dr. Broc...	Estate of Brock (1996) litigated reformation of a will in the Florida appellate courts; the outcome could not be classified. Alleged error: scriveners_error. Reformation regime in force: pre-statute.
1,137,165	1,137,165	Kelson v. Kelson	fladistctapp	1,994	15	contract	uncertain	equitable	mutual_mistake	1	Michelle Kelson argues that this is the functional equivalent of the retired pay she is entitled to share under the parties' agreement and that the failure of the parties to anticipate the possibility of Voluntary Separation Incentive payments in lieu of retirement benefits was a mutual mistake of fact resulting from t...	Kelson v. Kelson (1994) litigated reformation of a contract in the Florida appellate courts; the outcome could not be classified. Alleged error: mutual_mistake. Reformation regime in force: equitable.
1,139,086	1,139,086	National American Ins. Co. v. BAXLEY EX REL. BAXLEY	fladistctapp	1,991	5	insurance	uncertain	equitable	scriveners_error,mutual_mistake	5	The trial court also denied NAIC's motion for reformation of the policy based on mutual mistake.	National American Ins. Co. v. BAXLEY EX REL. BAXLEY (1991) litigated reformation of an insurance policy in the Florida appellate courts; the outcome could not be classified. Alleged error: scriveners_error, mutual_mistake. Reformation regime in force: equitable.
1,140,201	1,140,201	Ali Ghahramani, Md v. Pablo Guzman, Md	fladistctapp	2,000	9	contract	rule_stated	equitable	mutual_mistake,unilateral_mistake	3	These conditions were not alleged by Ghahramani to exist and, thus, the general rule requiring a mutual mistake to set aside the agreement applies. [2] The settlement agreement did not constitute a novation of the original agreement because Ghahramani was still obligated to pay the subject monies to Guzman and no new...	Ali Ghahramani, Md v. Pablo Guzman, Md (2000) litigated reformation of a contract in the Florida appellate courts; the opinion states the reformation rule without holding on it. Alleged error: mutual_mistake, unilateral_mistake. Reformation regime in force: equitable.
1,143,433	1,143,433	State Board of Control v. Clutter Construction Corporation	fladistctapp	1,962	18	contract	authority	equitable	unilateral_mistake	1	Appellant relies for reversal upon the decision rendered by the Supreme Court in Graham v. Clyde. [3] In the Graham case relief was denied a bidder who sought to withdraw his bid on a public contract because of a unilateral mistake.	State Board of Control v. Clutter Construction Corporation (1962) litigated reformation of a contract in the Florida appellate courts; the opinion discusses reformation authority rather than holding. Alleged error: unilateral_mistake. Reformation regime in force: equitable.
1,146,596	1,146,596	Brown v. Brown	fladistctapp	1,986	8	deed	sought	equitable	mutual_mistake	11	The daughter-in-law counterclaimed, alleging a "mutual mistake," as the 80 acre tract did not include the house, and sought to have the father's deed reformed to include land which would include the house.	Brown v. Brown (1986) litigated reformation of a deed in the Florida appellate courts; reformation was sought; the decision does not state the outcome in a sentence naming the remedy. Alleged error: mutual_mistake. Reformation regime in force: equitable.
1,146,762	1,146,762	Babcock v. United Services Auto. Ass'n	fladistctapp	1,987	6	insurance	uncertain	equitable	unspecified	1	Babcock and Dunn filed suit against USAA claiming primarily that the coverage provided by the written policy did not match the coverage requested by Babcock and consequently, that the written policy should be reformed to comport with his oral request.	Babcock v. United Services Auto. Ass'n (1987) litigated reformation of an insurance policy in the Florida appellate courts; the outcome could not be classified. Alleged error: unspecified. Reformation regime in force: equitable.
1,148,961	1,148,961	Lemon v. Groninger	fladistctapp	1,998	8	contract	authority	equitable	unspecified	1	(See paragraph 2 of that agreement between the bank, the Lemons and South-Groninger Homes, Inc. wherein it states that in the event of a conflict between the loan agreement and the construction contract, the loan agreement shall take precedence.) [2] Those counts were: breach of contract, reformation, accounting and ...	Lemon v. Groninger (1998) litigated reformation of a contract in the Florida appellate courts; the opinion discusses reformation authority rather than holding. Alleged error: unspecified. Reformation regime in force: equitable.
1,149,271	1,149,271	Antonelli v. Smith	fladistctapp	1,989	7	deed	authority	equitable	mutual_mistake	14	Department of Transp. v. Ronlee, 518 So.2d 1326 (Fla. 3d DCA 1987) (appellant waived right to reformation or rescission of contract by knowing of mistake ten days before commencement of construction and performing under contract for twenty-one months after such knowledge), review denied, 528 So.2d 1183 (Fla. 1988);	Antonelli v. Smith (1989) litigated reformation of a deed in the Florida appellate courts; the opinion discusses reformation authority rather than holding. Alleged error: mutual_mistake. Reformation regime in force: equitable.
1,149,361	1,149,361	Kraemer v. GMAC	fladistctapp	1,989	20	insurance	sought	equitable	unspecified	1	That complaint also contained a request for reformation of an insurance policy that is not at issue on appeal.	Kraemer v. GMAC (1989) litigated reformation of an insurance policy in the Florida appellate courts; reformation was sought; the decision does not state the outcome in a sentence naming the remedy. Alleged error: unspecified. Reformation regime in force: equitable.
1,150,383	1,150,383	Elliott v. Krause	fla	1,987	8	will	uncertain	pre-statute	scriveners_error	2	Albury makes clear, however, that evidence of a testator's intent should guide a court's decision to disregard a scrivener's error.	Elliott v. Krause (1987) litigated reformation of a will in the Florida appellate courts; the outcome could not be classified. Alleged error: scriveners_error. Reformation regime in force: pre-statute.
1,151,360	1,151,360	Campbell v. Campbell	fladistctapp	1,986	14	will	uncertain	pre-statute	scriveners_error	1	NOTES [1] They proffered two areas of testimony: (a) their own depositions which stated that only the named beneficiaries, together with Harold before his retirement, were active in the operation of the Williamsport business; thus indicating the unlikelihood that Harold would have desired that any interest pass to...	Campbell v. Campbell (1986) litigated reformation of a will in the Florida appellate courts; the outcome could not be classified. Alleged error: scriveners_error. Reformation regime in force: pre-statute.
1,151,834	1,151,834	In Re Estate of Reese	fladistctapp	1,993	3	will	sought	pre-statute	unspecified	4	Petitioners contend the probate court erroneously characterized their petition as one seeking reformation of the will.	In Re Estate of Reese (1993) litigated reformation of a will in the Florida appellate courts; reformation was sought; the decision does not state the outcome in a sentence naming the remedy. Alleged error: unspecified. Reformation regime in force: pre-statute.
1,152,346	1,152,346	Chanrai Investments, Inc. v. Clement	fladistctapp	1,990	10	deed	sought	equitable	unspecified	12	As a matter of law, reformation does not lie in this action in that Kingsland was not a party to the instrument sought to be reformed.	Chanrai Investments, Inc. v. Clement (1990) litigated reformation of a deed in the Florida appellate courts; reformation was sought; the decision does not state the outcome in a sentence naming the remedy. Alleged error: unspecified. Reformation regime in force: equitable.
1,553,627	1,553,627	Rachid v. Perez	fladistctapp	2,010	7	contract	authority	equitable	unilateral_mistake	4	See Tilden Groves, 816 So.2d at 660 (“[Clases settled in mediation are especially unsuited for the liberal application of a rule allowing rescission of a settlement agreement based on unilateral mistake.”); see also Sponga v. Warro, 698 So.2d 621, 625 (Fla. 5th DCA 1997).	Rachid v. Perez (2010) litigated reformation of a contract in the Florida appellate courts; the opinion discusses reformation authority rather than holding. Alleged error: unilateral_mistake. Reformation regime in force: equitable.
1,557,956	1,557,956	United Automobile Insurance Co. v. Salgado	fladistctapp	2,009	19	insurance	authority	equitable	mutual_mistake	1	(2) material to the risk assumed by the insurer; or (3) the insurer in good faith would not have issued the policy or would have done so only on different terms if the insurer had known the true facts. 3 As explained by the Supreme Court in Continental Assurance Co. v. Carroll, 485 So.2d 406, 409 (Fla.1...	United Automobile Insurance Co. v. Salgado (2009) litigated reformation of an insurance policy in the Florida appellate courts; the opinion discusses reformation authority rather than holding. Alleged error: mutual_mistake. Reformation regime in force: equitable.
1,564,698	1,564,698	KT Holdings USA, Inc. v. Akerman, Senterfitt & Eidson	fladistctapp	2,010	1	deed	authority	equitable	scriveners_error,mutual_mistake	9	Harris v. Uhlendorf, 24 N.Y.2d 463 , 301 N.Y.S.2d 53 , 248 N.E.2d 892, 894 (1969); see also Circle Mortgage Corp. v. Kline, 645 So.2d 75, 78 (Fla. 4th DCA 1994) ("A mistake is mutual when the parties agree to one thing and then, due to either a scrivener's error or inadvertence, express something different in the writt...	KT Holdings USA, Inc. v. Akerman, Senterfitt & Eidson (2010) litigated reformation of a deed in the Florida appellate courts; the opinion discusses reformation authority rather than holding. Alleged error: scriveners_error, mutual_mistake. Reformation regime in force: equitable.
1,564,842	1,564,842	Schmachtenberg v. Schmachtenberg	fladistctapp	2,010	8	contract	sought	equitable	unspecified	2	NOTES [1] The petition also sought reformation of the parties' agreement regarding transfer of title of the condominium in which their son lived.	Schmachtenberg v. Schmachtenberg (2010) litigated reformation of a contract in the Florida appellate courts; reformation was sought; the decision does not state the outcome in a sentence naming the remedy. Alleged error: unspecified. Reformation regime in force: equitable.
1,579,730	1,579,730	Ferreira v. Home Depot/Sedgwick CMS	fladistctapp	2,009	14	contract	uncertain	equitable	unspecified	1	Claimant challenges an order of the Judge of Compensation Claims (JCC) granting the Employer/Carrier’s (E/C) Motion for Repayment of Seed Money, arguing the JCC erred by reforming a final contract of settlement between the parties.	Ferreira v. Home Depot/Sedgwick CMS (2009) litigated reformation of a contract in the Florida appellate courts; the outcome could not be classified. Alleged error: unspecified. Reformation regime in force: equitable.
1,585,572	1,585,572	Brecker v. Furman	fladistctapp	1,987	5	contract	authority	equitable	unspecified	1	However, in a footnote, the appellate court recognized that contracts may be drafted in such a way as to award damages for the total amount to be paid: Since parties to the contract have the power to provide for remedies, Vol 5 A Corbin on Contracts § 1227, an alert scrivener may properly draft an instrument that avo...	Brecker v. Furman (1987) litigated reformation of a contract in the Florida appellate courts; the opinion discusses reformation authority rather than holding. Alleged error: unspecified. Reformation regime in force: equitable.
1,586,574	1,586,574	Peerless Insurance Co. v. Sun Line Helicopters, Inc.	fladistctapp	1,965	13	insurance	uncertain	equitable	unspecified	1	Peerless Insurance Company, one of the defendants below, appeals a final judgment rendered for a co-defendant, Plastic Components Construction, Inc., [hereafter Plastic Components] and the plaintiff, Sun Line Helicopters, Inc., in an action for reformation of an insurance contract or, in the alternative, for damages. ...	Peerless Insurance Co. v. Sun Line Helicopters, Inc. (1965) litigated reformation of an insurance policy in the Florida appellate courts; the outcome could not be classified. Alleged error: unspecified. Reformation regime in force: equitable.
1,587,907	1,587,907	Daughtrey v. Daughtrey	fladistctapp	2,006	15	deed	uncertain	equitable	wrong_description,scriveners_error	1	DISCUSSION There is no evidence in the record to support the trial court's conclusion that the use of the legal description of the two-acre parcel in the Wife's petition, in the Settlement Agreement, and in the quitclaim deed that the Husband had already executed was the result of "a scrivener's error." [2] As this c...	Daughtrey v. Daughtrey (2006) litigated reformation of a deed in the Florida appellate courts; the outcome could not be classified. Alleged error: wrong_description, scriveners_error. Reformation regime in force: equitable.
1,588,832	1,588,832	Leff v. Ecker	fladistctapp	2,007	3	contract	uncertain	equitable	mutual_mistake	2	We are not persuaded by the plaintiff's argument that mutual mistake allows him to avoid the parties' agreement, reached after a mediation conference.	Leff v. Ecker (2007) litigated reformation of a contract in the Florida appellate courts; the outcome could not be classified. Alleged error: mutual_mistake. Reformation regime in force: equitable.
1,589,996	1,589,996	Lennar Homes, Inc. v. Dorta-Duque	fladistctapp	2,007	1	contract	authority	equitable	omitted_provision,mutual_mistake	4	Providence Square Ass'n, Inc. v. Biancardi, 507 So.2d 1366, 1369-70 (Fla.1987) ("A court of equity has the power to reform a written instrument where, due to a mutual mistake, the instrument as drawn does not accurately express the true intention or agreement of the parties to the instrument. . . .	Lennar Homes, Inc. v. Dorta-Duque (2007) litigated reformation of a contract in the Florida appellate courts; the opinion discusses reformation authority rather than holding. Alleged error: omitted_provision, mutual_mistake. Reformation regime in force: equitable.
1,592,934	1,592,934	BARNACLE BILL'S SEAFOOD v. Ford	fladistctapp	1,984	6	contract	uncertain	equitable	mutual_mistake	3	The doctrine of mutual mistake is not applicable under the facts here since, by definition, the mutual mistake of fact must be of a fact existing at the time of the contract and not as to a future event. [5] The abolition of the Okaloosa Island Authority occurred years after the contract was entered into.	BARNACLE BILL'S SEAFOOD v. Ford (1984) litigated reformation of a contract in the Florida appellate courts; the outcome could not be classified. Alleged error: mutual_mistake. Reformation regime in force: equitable.
1,593,833	1,593,833	Flanigan's Enterprises v. Shoppes at 18th	fladistctapp	2,007	6	contract	authority	equitable	scriveners_error	4	Because reformation is allowed against all persons, except bona fide purchasers for value and without notice, Fla. Masters Packing, Inc. v. Craig, 739 So.2d 1288 (Fla. 4th DCA 1999) (citing Holley v. May, 75 So.2d 696, 697 (Fla.1954)), we affirm the reformation of the 1992 amended settlement agreement.	Flanigan's Enterprises v. Shoppes at 18th (2007) litigated reformation of a contract in the Florida appellate courts; the opinion discusses reformation authority rather than holding. Alleged error: scriveners_error. Reformation regime in force: equitable.
1,594,348	1,594,348	Old Port Condo. Ass'n v. Old Port Holdings	fladistctapp	2,007	1	contract	uncertain	equitable	unspecified	1	If Owner thought that the right of first refusal was enduring too long, that the parties really intended that it not last as long as their agreement might suggest, it certainly had the right to bring an action under the statute to reform the right.	Old Port Condo. Ass'n v. Old Port Holdings (2007) litigated reformation of a contract in the Florida appellate courts; the outcome could not be classified. Alleged error: unspecified. Reformation regime in force: equitable.
1,595,712	1,595,712	Malt v. Deese	fladistctapp	1,981	4	contract	uncertain	equitable	unspecified	1	(3) cancellation for Deese's misrepresentation that the patented product was a marketable commodity; and (4) reformation of the contract to reflect a purchase price of $200,000.	Malt v. Deese (1981) litigated reformation of a contract in the Florida appellate courts; the outcome could not be classified. Alleged error: unspecified. Reformation regime in force: equitable.
1,596,231	1,596,231	Lumbermens Mut. Cas. Co. v. Martin	fladistctapp	1,981	24	insurance	granted	equitable	unspecified	1	(b) In view of the clear and unrebutted testimony that a simple mistake had been made, the policy was properly reformed to change the named insured from Felix Martin to Francisco Martin, Sr., the father of the decedent, Francisco, Jr.;	Lumbermens Mut. Cas. Co. v. Martin (1981) litigated reformation of an insurance policy in the Florida appellate courts; the court granted reformation. Alleged error: unspecified. Reformation regime in force: equitable.
1,597,294	1,597,294	Nordberg v. Green	fladistctapp	1,994	8	deed	authority	equitable	mutual_mistake	5	Flagler, 94 So.2d at 594 ; accord Schwartz v. Zaconick, 68 So.2d 173, 176 (Fla. 1953) ("with respect to such fundamental rules of law as the one here, equity must follow the law unless some recognized principle permits otherwise"). [3] For these reasons, the judgment in Mrs. Green's favor "reforming" the deed to elim...	Nordberg v. Green (1994) litigated reformation of a deed in the Florida appellate courts; the opinion discusses reformation authority rather than holding. Alleged error: mutual_mistake. Reformation regime in force: equitable.
1,599,290	1,599,290	USAA Cas. Ins. Co. v. Threadgill	fladistctapp	1,999	9	deed	granted	equitable	omitted_provision,scriveners_error,mutual_mistake,unilateral_mistake	26	There, this court affirmed a trial court's reformation of a note and adjustable rate mortgage which failed to contain an interest rate change date that had been specified in a previously signed disclosure form which contained the parties' agreement.	USAA Cas. Ins. Co. v. Threadgill (1999) litigated reformation of a deed in the Florida appellate courts; the court granted reformation. Alleged error: omitted_provision, scriveners_error, mutual_mistake, unilateral_mistake. Reformation regime in force: equitable.
1,599,623	1,599,623	Smith v. Harr	fladistctapp	1,990	5	insurance	uncertain	equitable	mutual_mistake	1	In the reassignment CFDC's insuror stated that the release was intended to bind only Smith and CFDC: Whereas, Paul R. Smith was involved in an automobile accident on July 7, 1983 with a vehicle owned by Central Florida Distributing and Whereas, Central Florida Distributing, it's employees, agents and servants inclu...	Smith v. Harr (1990) litigated reformation of an insurance policy in the Florida appellate courts; the outcome could not be classified. Alleged error: mutual_mistake. Reformation regime in force: equitable.
1,603,674	1,603,674	CIRCLE MORTG. CORP. v. Kline	fladistctapp	1,994	17	deed	granted	equitable	scriveners_error,mutual_mistake	13	Appellant, Circle Mortgage Corporation (Circle Mortgage), plaintiff below, appeals from a final judgment granting reformation of a mortgage, but not damages.	CIRCLE MORTG. CORP. v. Kline (1994) litigated reformation of a deed in the Florida appellate courts; the court granted reformation. Alleged error: scriveners_error, mutual_mistake. Reformation regime in force: equitable.
1,606,983	1,606,983	Petersen v. Brotman	fladistctapp	1,958	11	contract	uncertain	equitable	unspecified	1	This is an interlocutory appeal from an order dated September 26, 1957 denying a motion to dismiss an amended complaint in an action by Jonas J. Brotman against Henry Petersen and Anna E. Petersen, his wife, for the reformation of and specific performance of a contract for the sale of real property.	Petersen v. Brotman (1958) litigated reformation of a contract in the Florida appellate courts; the outcome could not be classified. Alleged error: unspecified. Reformation regime in force: equitable.
1,611,147	1,611,147	Lechuga v. Flanigan's Enterprises, Inc.	fladistctapp	1,988	9	contract	authority	equitable	unilateral_mistake	4	Maryland Casualty Co. v. Krasnek, 174 So.2d 541 (Fla. 1965); compare Department of Transp. v. Ronlee, Inc., 518 So.2d 1326 (Fla. 3d DCA 1987) (rescission not available for unilateral mistake where bidder on public contract is negligent and tardy), rev. denied, 528 So.2d 1183 (Fla. 1988).	Lechuga v. Flanigan's Enterprises, Inc. (1988) litigated reformation of a contract in the Florida appellate courts; the opinion discusses reformation authority rather than holding. Alleged error: unilateral_mistake. Reformation regime in force: equitable.
1,611,268	1,611,268	STATE, DNR v. Antioch University	fladistctapp	1,988	12	deed	authority	equitable	unspecified	1	It next contended that the suit was not subject to the LAR in that suits seeking rescission, cancellation or reformation of a deed or specific performance of a contract to convey land are in personam, Greene v. A.G.B.B.	STATE, DNR v. Antioch University (1988) litigated reformation of a deed in the Florida appellate courts; the opinion discusses reformation authority rather than holding. Alleged error: unspecified. Reformation regime in force: equitable.
1,611,960	1,611,960	Ryan v. Lobo De Gonzalez	fladistctapp	2,003	18	trust	uncertain	pre-statute	mutual_mistake	3	The following claims were asserted: constructive trust, reformation for mutual mistake, breach of fiduciary duty, declaratory judgment, negligent misrepresentation and permanent injunction.	Ryan v. Lobo De Gonzalez (2003) litigated reformation of a trust in the Florida appellate courts; the outcome could not be classified. Alleged error: mutual_mistake. Reformation regime in force: pre-statute.
1,612,466	1,612,466	Negron v. Travelers Insurance Company	fladistctapp	1,973	10	deed	uncertain	equitable	unspecified	2	"(2) Is the driver of a United States Postal vehicle owned by the United States Government and used in the course and scope of United States Postal service business entitled to personal injury protection benefits under a policy of insurance written on his private automobile under Sections [627.736(4)(d)(1)] *29 and [62...	Negron v. Travelers Insurance Company (1973) litigated reformation of a deed in the Florida appellate courts; the outcome could not be classified. Alleged error: unspecified. Reformation regime in force: equitable.

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Florida Reformation of Instruments, 1853-2026

Every Florida state appellate decision litigating the reformation of a legal instrument -- will, trust, deed, contract or insurance policy -- with the instrument type, the kind of drafting error alleged, the outcome, and which statutory regime was in force. Florida authorised trust reformation in 2007 (s. 736.0415) and will reformation in 2011 (s. 732.615); before those dates the remedy rested on equity, and for wills was unavailable entirely. The dataset makes that break observable within one jurisdiction.

932 rows. Licence CC BY 4.0. Not legal advice.

Where this comes from


Canonical record	https://doi.org/10.5281/zenodo.22247377
Code and methodology	https://github.com/stepuplaw/legal-empirics
Research page	https://stepuplaw.com/research/
Author	Kevin D. Klagge, ORCID 0009-0002-1385-8498
Source corpus	CourtListener bulk export, snapshot 2026-06-30

The DOI above identifies the code, which is a different object from this dataset. Cite the code when you are describing the method and cite this dataset when you are using the numbers.

Columns

Column	Type	Meaning
`oid`	integer	CourtListener opinion id
`cid`	integer	CourtListener cluster id; one decision may hold several opinions
`name`	string	case name as reported
`court`	string	CourtListener court id (fla = Supreme Court of Florida, fladistctapp = District Courts of Appeal)
`year`	integer	year the decision was filed
`cites`	integer	times the decision has been cited, per CourtListener
`instrument`	string	will
`outcome`	string	granted
`regime`	string	statutory
`errors`	string	comma-separated error types alleged; multi-label by design
`n_reform_sents`	integer	count of reformation sentences found in the opinion
`cites_statute`	integer	1 where the opinion cites s. 732.615, s. 732.616 or s. 736.0415
`key_sentence`	string	the sentence the outcome label was read from, verbatim
`statement`	string	the row written as one self-contained English sentence, so it can be retrieved, quoted and checked on its own

Every row carries a statement column, which is the row written as one self-contained English sentence. A row of codes can be downloaded but not retrieved or quoted, and the sentence is what makes each row usable on its own.

How it was built

Retrieval and extraction are deterministic code over a local corpus of 10.8M US judicial opinions. Classification uses rules written against a hand-coded sample that ship with their measured accuracy, so the error rate is reported rather than assumed. Every study states its exclusion funnel with counts, because silent filtering is the commonest defect in research on opinions and it is invisible in the result.

datapackage.json carries the Frictionless schema, croissant.json the MLCommons Croissant description, and dataset.jsonld the schema.org form.

Limits

This is exploratory. The coded samples behind it were coded once, so it supports a described pattern rather than a measurement. Inter-annotator reliability has not been established.

Published appellate opinions are not disputes. Most disputes settle, most settlements are unpublished, and appellate coverage varies by court and decade. Any rate here is a rate among decisions that reached an appellate court and were published, which is not the same population a drafter cares about.

Read the study's own limitations section in the repository before quoting a number. Each one names the specific threats to its own validity, including the ones that are unflattering.

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