Sometimes the interpretation of a single word can alter the course of litigation. In a recent decision involving two Florida mobile home park associations, a single article, “a,” reshaped how entire communities must pursue relief in court.[i] In Wynne Building Corporation v. Spanish Lakes Country Club Village Homeowner’s Association, Inc., the Florida Fourth District Court of Appeal clarified how Florida Rule of Civil Procedure 1.222 governs associational class actions in mobile home parks.

Florida Rule of Civil Procedure 1.222 was created with mobile home communities in mind.[ii] Residents in these parks typically own their homes but lease the land beneath them, meaning disputes over rent increases or shared facilities tend to affect every homeowner.[iii] Recognizing this dynamic, the rule allows a mobile homeowners’ association to bring a lawsuit in its own name on behalf of all homeowners concerning matters of common interest.[iv] Unlike traditional class actions governed by Rule 1.220, this procedure does not require the association to satisfy the full set of certification requirements. Instead, Rule 1.222 serves as a practical shortcut, providing mobile homeowners with a collective voice without the complexity of conventional class-action litigation.[v]

In Wynne, two separate homeowners’ associations representing neighboring parks—both owned by Wynne Building Corporation—filed a single joint class action challenging allegedly unreasonable rent increases over a two-year period. The trial court allowed them to proceed together under Rule 1.222. On appeal, the Fourth District reversed. The court did not decide whether the rent increases were reasonable; instead, it focused on how such challenges must be structured from the outset.

The court’s attention turned to the language of Rule 1.222. By its terms, the rule allows “[a] mobile homeowners’ association” to bring an action on behalf of its homeowners, and the majority read this phrasing literally. The singular references, along with the later use of “the association,” suggested to the court that each action must be brought by one specific association for its own members. What the court would not allow was a “class action of class actions,” a combined suit representing multiple associations together, since each association is legally distinct and represents a separate group of homeowners.[vi] In reaching this conclusion, the court relied on textualist principles, echoing reasoning from Ham v. Portfolio Recovery Associates, LLC, emphasizing that the interpretation of a procedural rule must be faithful to the meaning the text can reasonably bear.[vii]

The ruling does not shut the door on collective action; instead, it redraws the path to get there. Associations may still pursue related claims in parallel, and their cases may ultimately proceed together. Each association must first establish independently that its claims involve matters of common interest among its own members under Rule 1.222. Only once that separate certification is complete can the trial court, exercising its broad discretion, consolidate the cases for efficiency.[viii] In reaffirming this approach, the court emphasized that judges retain “maximum discretion” in managing their dockets, enforcing precedent from Condominium Owners Organization of Century Village East, Inc. v. Century Village East, Inc.[ix] Consolidation remains an option, but it comes only after each association has cleared the initial procedural threshold.

The dissent viewed this requirement as an unnecessary procedural detour. Because the defendants’ alleged conduct and the governing legal theories were identical, it questioned whether forcing separate filings elevates form over substance. Moreover, separate commonality inquiries and layered motion practices may increase attorneys’ fees and litigation costs. Given that fee-shifting provisions often apply in mobile home park disputes, those additional expenses may ultimately fall on the losing party.

The ruling leaves substantive rights untouched. Mobile homeowners may still collectively challenge rent increases. However, the structure for bringing these cases together has shifted. Even when multiple parks confront identical rent hikes from the same owner, they must initiate separate Rule 1.222 actions before seeking consolidation. The decision illustrates how procedural language—down to “a” single article—can recalibrate leverage, timing, and cost.

Under Florida law, collective action in mobile home park disputes still exists, but it now begins one association at a time.

[i] Wynne Bldg. Corp. v. Spanish Lakes Country Club Vill. Homeowners Ass’n, Inc., No. 4D2025-2169, at 2 (Fla. 4th DCA Feb. 11, 2026) (holding that Rule 1.222 permits an action by a single association on behalf of its members but does not authorize a joint associational class action brought by multiple associations).

[ii] Fla. R. Civ. P. 1.222.

[iii] Fla. Stat. § 723.003 (2025) (defining mobile home lot tenancy).

[iv] Fla. R. Civ. P. 1.222; Fla. R. Civ. P. 1.220.

[v] Id.

[vi] Condo. Owners Org. Century Village E., Inc. v. Century Village E., Inc., 428 So.2d 384, 386 (Fla. 4th DCA 1983) (holding that an umbrella organization cannot bring a “class action of class actions” on behalf of multiple condominium associations).

[vii] Ham v. Portfolio Recovery Assocs., LLC, 308 So.3d 942, 947 (Fla. 2020).

[viii] Fla. R. Civ. P. 1.270(a).

[ix] Condo. Owners Org. Century Village E., 428 So.2d at 386.