Miami Jury Awards $502K to Raymond Del Valle in Crash
Table of Contents
Case Background
A Miami-Dade County jury returned a verdict on April 22, 2025, finding the Defendant, Alexander Mosquera, negligent in a civil action filed by Plaintiff Raymond Del Valle. The lawsuit, lodged in the Circuit Court of the 11th Judicial Circuit, sought to recover damages for personal injuries Mr. Del Valle sustained in a motor vehicle accident. The Plaintiff had named both the driver and the corporate entity, Tiger & Son Roofing Company, as Defendants.
Cause
The complaint, filed in January 2023, alleged that the Defendant driver, Alexander Mosquera, operated his vehicle negligently, and that this negligence directly caused the collision with Mr. Del Valle. The Plaintiff's legal theory centered on the driver’s failure to maintain due regard for the safety of others on the roadway, resulting in the crash that inflicted injury. The complaint further implicated Tiger & Son Roofing Company, alleging that the company owned the Dodge Truck driven by Mr. Mosquera and that the company had a non-delegable duty under Florida's dangerous instrumentality doctrine, making it vicariously liable for the driver's actions.
Injury
As a direct consequence of the collision, the Plaintiff, Raymond Del Valle, claimed to have suffered serious and permanent injuries in and about his body. These injuries included bodily harm and resulting pain and suffering, physical disability, disfigurement, and the loss of capacity for the enjoyment of life. The complaint specified that the injuries were either permanent or continuing and that the Plaintiff would face these losses, along with ongoing medical expenses, into the future. Furthermore, Mr. Del Valle asserted that the Defendant's actions had aggravated a previously existing condition or activated a latent physical defect, entitling him to damages for the entire resulting injury.
Damages Sought
Mr. Del Valle sought compensation for all losses and damages he had sustained, which he claimed exceeded the jurisdictional minimum of thirty thousand dollars. Specifically, the Plaintiff demanded judgment for the following categories of damages:
Medical and Hospital Expenses: Costs for past and future hospitalization, medical and nursing care, and treatment required for his injuries.
Lost Wages and Earning Capacity: Compensation for wages he had lost and the diminished ability to earn money in the future.
Non-Economic Damages: Recovery for pain and suffering, disability, physical impairment, mental anguish, inconvenience, aggravation of a pre-existing condition, and loss of capacity for the enjoyment of life.
Key Arguments and Proceedings
The case proceeded to trial after the Defendants had denied the core allegations and asserted several defenses. The primary focus of the proceedings became whether Mr. Mosquera’s actions truly constituted negligence and whether Mr. Del Valle’s injuries met the legal standard for permanence.
Legal Representation
Plaintiff(s): Raymond Del Valle.
· Counsel for Plaintiff(s): Nelson T. Pena
· Experts for Plaintiff(s): Andrew Schmer | Kevin McGrath | Osama Gomaa | Modesto Sanchez Torres | Michael D’Angelo | Aaron B. Moss | Ignacio Rodriguez
Defendant(s): Tiger & Son Roofing Company, Juan Perez, and Alexander Mosquera.
· Counsel for Defendant(s): Hugo V. Alvarez | Roberta Tejchman | Christopher T Corkran | Mayada Al Hussaini
· Experts for Defendant(s): Jon D. Donshik
Key Arguments or Remarks by Counsel
Claims
The Plaintiff’s counsel argued that the Defendant driver, Alexander Mosquera, operated his vehicle carelessly and that his negligence directly and proximately caused the accident and Mr. Del Valle’s injuries. The core claim against the corporate entity, Tiger & Son Roofing Company, was based on the Dangerous Instrumentality Doctrine, which imposes strict vicarious liability on the owner of a vehicle for the driver's negligence when the driver operates the vehicle with the owner’s consent. The Plaintiff asserted that, as the owner of the truck, Tiger & Son Roofing Company became legally responsible for the driver's negligence, regardless of whether the driver was an employee or an independent contractor.
Defense
The Defendants mounted a multifaceted defense. Their answer to the complaint categorically denied the allegations of negligence on the part of Mr. Mosquera.
Affirmative Defenses
Comparative Negligence: The defense claimed that Mr. Del Valle’s own negligence or fault contributed to the accident, arguing that the Court should reduce any award based on his share of the blame.
Failure to Mitigate: The Defendants argued that Mr. Del Valle had failed to take reasonable steps to limit the extent of his injuries or damages after the accident.
Seatbelt Defense: The defense raised a specific claim that Mr. Del Valle might not have been wearing a fully functioning seatbelt, suggesting that this failure contributed to his injuries and should serve as an additional basis for finding comparative fault.
Lack of Permissive Use: Tiger & Son Roofing Company argued that they had not authorized or consented to the co-Defendant’s use of the vehicle at the time of the accident, aiming to negate the corporate liability claims based on the Dangerous Instrumentality Doctrine.
Jury Verdict
The jury concluded deliberations and returned a verdict firmly in favor of the Plaintiff on April 22, 2025.
The jury first answered the crucial question regarding negligence, finding that the negligence of the Defendant, Alexander Mosquera, was a legal cause of loss, injury, or damage to Raymond Del Valle.
The jury awarded the following total amounts for damages sustained by Mr. Del Valle:
Economic Damages (Medical Expenses)
The jury fully compensated the Plaintiff for his medical care costs, awarding:
Medical Expenses Incurred in the Past: $52,923.76
Medical Expenses to be Incurred in the Future: $200,000.00
Non-Economic Damages (Pain and Suffering)
Acknowledging the finding of a permanent injury, the jury awarded substantial non-economic damages for the Plaintiff's pain and suffering, disability, physical impairment, mental anguish, inconvenience, aggravation of a disease or physical defect, and loss of capacity for the enjoyment of life:
Sustained in the Past: $100,000.00
To be Sustained in the Future: $150,000.00
The jury calculated the total damages awarded to Raymond Del Valle at $502,923.76 (Five Hundred Two Thousand, Nine Hundred Twenty-Three Dollars, and Seventy-Six Cents).
This decisive verdict established the Defendant driver's full responsibility for the collision and recognized the serious, permanent consequences suffered by the Plaintiff, ensuring Mr. Del Valle received full compensation for both his past and future medical costs and for the enduring pain and suffering resulting from the accident.