## Facts

- Jill Horkheimer held an uninsured/underinsured motorist (UM) policy issued by State Farm Mutual Automobile Insurance Company with stacked UM limits alleged in the complaint to total $50,000.
- Horkheimer was injured in an automobile accident involving an underinsured motorist and sought UM benefits under her State Farm policy.
- State Farm refused to pay the claim, and Horkheimer sued State Farm seeking contractual UM benefits up to the $50,000 policy limit she alleged.
- The complaint did not seek damages beyond the policy limits and did not assert a bad-faith or other extra-contractual theory of recovery.
- State Farm was validly served and had notice of the lawsuit but filed no answer or other responsive pleading.
- Approximately nine months after service, Horkheimer obtained a clerk’s default against State Farm.
- The case proceeded to a jury trial limited to damages; State Farm did not appear.
- The verdict form asked only for the amount of Horkheimer’s damages, and the jury returned a verdict of $1,075,092.
- The trial court entered a final judgment for the verdict amount and also awarded attorney’s fees, interest, and costs, bringing the total judgment to more than $1.2 million.
- State Farm moved for relief under Florida Rule of Civil Procedure 1.540(b), asking the court to set aside the final judgment and/or conform the judgment to the $50,000 UM limits alleged in the complaint.
- The trial court denied relief, reasoning that State Farm had notice of the default and the trial settings.

## Issues

1. Whether, after a default in a UM contract action with no bad-faith claim, the trial court may enter a final judgment for damages exceeding the UM policy limits alleged in the complaint.
2. Whether entry of a judgment that exceeds the relief demanded in the pleadings is a “mistake” that warrants relief under Florida Rule of Civil Procedure 1.540(b).

## Decision

- The Fourth District Court of Appeal reversed the order denying State Farm’s Rule 1.540(b) motion.
- The court held that the final judgment could not stand because it exceeded the policy limits and relief requested in the complaint.
- The court concluded the excess judgment constituted a correctable “mistake” under Rule 1.540(b).
- The court remanded with directions to limit Horkheimer’s recovery against State Farm to the $50,000 UM coverage limits alleged in the pleadings.
- The court also remanded for the trial court to reconsider attorney’s fees in light of the reduced judgment.

## Legal Principles

- A default admits the well-pleaded allegations of the complaint as to liability, but it does not authorize a judgment granting relief different in kind or greater in amount than what the pleadings request.
- In a UM benefits lawsuit pled as a contract claim, absent a bad-faith or other extra-contractual claim, the insurer’s payment obligation is capped by the UM policy limits sought in the complaint.
- Entering a final judgment after default for an amount that exceeds the maximum recovery requested in the pleadings is an error that may be treated as a “mistake” and corrected through relief from judgment under Florida Rule of Civil Procedure 1.540(b).
- Notice of trial settings does not permit a court to award damages beyond the scope of the relief demanded in the complaint when liability is established solely by default and the claim is confined to contractual policy benefits.

## Conclusion

State Farm Mutual Automobile Insurance Company v. Horkheimer holds that, in a UM contract action where the insured pleads and seeks only the policy limits and asserts no bad-faith claim, a post-default final judgment cannot exceed the pleaded UM limits; an excess judgment is a Rule 1.540(b) mistake requiring reversal, reduction to the $50,000 limits, and reconsideration of any fee award based on the corrected recovery.


State Farm Mutual Automobile Insurance Company v. Horkheimer, 814 So. 2d 1069 (2001)