In Special v. West Boca Medical Center, No. SC11-2511 (Fla. Nov. 13, 2014), plaintiff brought a medical malpractice action and, following a trial, the jury found in favor of defendants.  The appellate court affirmed, ruling that any error during the trial was harmless because it was more likely than not that the alleged errors did not contribute to the verdict.  The Florida Supreme Court reversed and, in so doing, articulated for the first time the proper test for harmless error in Florida civil appeals.  The court stated that it is insufficient merely to show that it was “more likely than not” that the error did not contribute to the judgment; rather, the beneficiary of the error must prove that there is “no reasonable possibility” that the error complained of contributed to the verdict.  In order to determine whether the beneficiary of the error has satisfied this burden, the appellate court should focus on the effect of the error on the trier-of-fact, and avoid engaging in an analysis that looks only to the result in a given case.