209 So. 3d 1199 (Fla. 2017) Attorney Chris Carlyle authored an amicus brief on behalf of the Florida Consumer Action Network in this important case addressing article X, section 25 of the Florida Constitution, more commonly known as “Amendment 7.” In the opinion, the Supreme Court of Florida held that the Federal Patient Safety and Quality Improvement Act did not expressly preempt Amendment 7. The Firm was on the prevailing side of the first major case interpreting Amendment 7 which attorney Chris Carlyle argued before the Florida Supreme Court. See Florida Hospital Waterman, Inc. v. Buster, 984 So. 2d 478 (Fla. 2008).