Goodyear Tire & Rubber Co. v. Schalmo
987 So. 2d 142 (Fla. 2d DCA 2008)
The occupants of a motor home sued various parties, including a tire company, after sustaining injuries in an accident involving a motor home. The occupants alleged that the accident occurred when the tread on one of the motor home's tires separated. Claims against the company included negligence and strict liability as to the design and manufacture of the tire. The occupants requested various documents in discovery, which the company objected to as confidential trade secrets and business information. Fearing that it would lose the ability to assert that the Sunshine in Litigation Act was inapplicable to particular documents sought in the discovery requests, the company asserted that the blanket confidentiality order covering all documents that was entered by the trial court was improper because the court had not performed an in-camera inspection of any documents. There was a suggestion that the tires were a "public hazard" under the, therefore, the appellate court held that an in-camera inspection was required by the express terms of the Act. If the tires were a public hazard, the documents could not be the subject of a confidentiality order under § 69.081(2) and (7) of the Act.