Most lawyers encounter Gateway Cable TV, Inc. v. Vikoa Construction Corp. early in their careers—usually as a case about contract formation without a signature. That is the holding, and it matters. But stopping there misses the more important lesson the case teaches about how Florida courts think about trials, evidence, and the proper role of juries.

At bottom, Gateway Cable is not really about signatures. It is about restraint—judicial restraint—and Florida’s long-standing reluctance to take cases away from juries when reasonable people could disagree about what the facts show.

The Surface Holding: Contracts Can Exist Without Formal Signatures

The formal issue in Gateway Cable was straightforward. The trial court directed a verdict for the defendant on the theory that no contract could exist because the written agreement required execution by two authorized officers at the defendant’s home office—and that never happened.

The First District reversed. It held that a contract may be binding even without a party’s signature where mutual assent is shown through conduct, reliance, and performance. Acceptance, the court reminded us, can be proven “by the acts or conduct of the parties,” not just by ink on a page.

That principle was not new even in 1971. What made Gateway Cable significant was how decisively the appellate court rejected the trial judge’s willingness to resolve that issue as a matter of law.

The Deeper Point: This Was Never a Directed Verdict Case

What stands out in Gateway Cable is not that the appellate court found a contract. It did not. Instead, it held that the evidence was sufficient for a jury to decide whether a contract existed.

That distinction matters.

The plaintiff presented evidence that:

• The deal was “hammered out” in person, with unresolved terms finalized by calls to the defendant’s home office.
• The defendant’s finance director told the plaintiff “we had a deal.”
• The defendant demanded and received the $5,000 deposit called for by the contract.
• The defendant negotiated the check and kept the money for weeks.
• The defendant encouraged performance while time was of the essence.
• The defendant only disavowed the deal after an internal policy change.

Reasonable jurors could conclude from those facts that the defendant accepted the contract and acted upon it—despite never formally signing it. That was enough.

The trial court erred not because it reached the “wrong” conclusion, but because it reached any conclusion at all.

Florida’s Longstanding Preference for Jury Determinations

Gateway Cable fits squarely within a broader Florida tradition: when intent, assent, reliance, or credibility are in dispute, juries decide.

Whether parties intended a writing to be binding.
Whether conduct amounted to acceptance.
Whether assurances induced reliance.
Whether performance confirms mutual assent.

These are classic jury questions. Florida courts have consistently resisted turning them into legal abstractions that can be disposed of by directed verdict.

The appellate court was explicit on this point:

“The intention of the parties is a fact to be decided upon the evidence.”

Once that is true, the judge’s role narrows dramatically.

Why Directed Verdicts Are (and Should Be) Rare

Directed verdicts are not supposed to be tools for “cleaning up” messy factual disputes. They exist for only one situation: where no reasonable jury could find for the non-moving party under any view of the evidence.

Gateway Cable illustrates how high that bar really is. Even with an unsigned contract and an express provision requiring execution, the surrounding conduct created a factual dispute that belonged to the jury.

That principle remains vital today. Trial courts are not arbiters of business fairness, wisdom, or internal corporate procedure. They are gatekeepers, not fact-finders.

The Enduring Lesson for Litigators

For litigators, Gateway Cable offers a practical reminder:

If your case involves:

• Mixed oral and written agreements,
• Performance before formal execution,
• Assurances followed by reliance,
• Conduct inconsistent with later repudiation,

then you are often closer to a jury question than opposing counsel would like to admit.

And if you are seeking a directed verdict in such a case, you should be prepared to explain why no reasonable juror could see the facts differently—not merely why you think the other side should lose.

Conclusion

Gateway Cable TV, Inc. v. Vikoa Construction Corp. is remembered as a contract case. Properly understood, it is a jury case.

It reflects a core feature of Florida jurisprudence: when reasonable people can disagree about what the parties intended or what their conduct meant, the system errs on the side of letting juries decide. That instinct—deeply embedded in Florida law—is not a flaw. It is a feature.

And it is why directed verdicts remain the exception, not the rule.