Florida Patient's Comp. Fund v. St. Paul Fire and Marine Ins. Co.

Summary

The Supreme Court of Florida affirmed the Fourth District Court of Appeal's dismissal of the Florida Patient's Compensation Fund's second contribution action, holding that res judicata bars the claim, that subrogation is unavailable without a contribution right, and that equitable assignment is not permissible. The Court also held that a promissory note does not satisfy the statutory cash‑payment requirement.