## Facts

- Frank L. Morsani and affiliated entities pursued acquisition of a Major League Baseball franchise during the 1980s and early 1990s.
- In 1984, Morsani alleged that majority owners of Minnesota Twins, Inc. agreed to sell a controlling interest to his group if his group first purchased a minority interest from another party.
- Morsani’s group purchased the minority interest for $11.5 million; the majority owners then sold their interest to another buyer.
- MLB and related defendants allegedly demanded that Morsani assign the minority interest to the new majority owner for $225,000, despite an alleged far higher value.
- Morsani alleged he agreed to the assignment based on MLB officials’ promises that he would be a leading candidate to obtain majority ownership in a franchise in time for the 1993 season, and that refusal would foreclose future ownership.
- Morsani never obtained any MLB team ownership interest; he later sued for, among other claims, tortious interference arising from the Twins-related events.
- MLB moved for summary judgment on the Twins-related tortious interference count as time-barred; Morsani conceded the limitations period had run but argued MLB should be equitably estopped from asserting the defense because its conduct induced delay in filing suit.

## Issues

1. Whether section 95.051, Florida Statutes (1993), which enumerates exclusive grounds for tolling statutes of limitation, prohibits application of equitable estoppel to bar a statute-of-limitations defense when the action was filed after the limitations period expired.
2. Whether equitable estoppel is legally distinct from statutory tolling for purposes of section 95.051’s exclusivity language.

## Decision

- The Florida Supreme Court answered the certified question in the negative.
- Section 95.051 does not prohibit the doctrine of equitable estoppel from barring a defendant’s statute-of-limitations defense.
- The court approved the district court’s resolution of the certified question and remanded for further proceedings consistent with recognizing equitable estoppel as available in this context.

## Legal Principles

- Tolling concerns when a limitations period begins to run and when its running is suspended; equitable estoppel operates differently by preventing a defendant from invoking a limitations defense when the defendant’s conduct induced the plaintiff to delay filing.
- Section 95.051 governs tolling only; its statement that no “disability or other reason” shall toll the statute beyond listed grounds does not address, and therefore does not eliminate, equitable estoppel.
- Statutes in derogation of the common law are strictly construed; common-law doctrines remain effective unless the Legislature clearly expresses an intent to abrogate them.
- Equitable estoppel may apply where a defendant’s representations or conduct reasonably induced a plaintiff to forbear timely suit, even though the limitations period otherwise expired.

## Conclusion

The Florida Supreme Court held that Florida’s exclusive statutory tolling provision does not abolish equitable estoppel, and a defendant may be barred from asserting a statute-of-limitations defense if the defendant’s conduct caused the plaintiff’s untimely filing.


Major League Baseball v. Morsani, 790 So. 2d 1071 (Fla. 2001)