Criminal Law: The State must prove actual physical control in a careless driving case -- State failed to prove that defendant was in actual physical control of vehicle where defendant had been transported to hospital before trooper arrived at scene of…

INSUREDS MAY NOT RECOVER EXTRA-CONTRACTUAL, CONSEQUENTIAL DAMAGES IN A FIRST-PARTY BREACH OF INSURANCE CONTRACT ACTION AGAINST CITIZENS  Citizens Property Ins. Co. v. Manor House, 46 Fla. L. Weekly S21 (Fla. January 21, 2021): In this case involving a first-party claim for…