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.

On March 11, 2026, the Fourth District Court of Appeal of Florida issued its per curiam opinion in Roussell v. Bank of New York Mellon, affirming the trial court’s judgment on the merits but writing separately to address a troubling issue: the appellant’s reliance on fabricated legal authority.[i] The court found that thirteen of the cases cited in the appellant’s brief did not exist and that nine additional citations, while referencing real cases, did not stand for the propositions the appellant attributed to them. The decision adds to a growing line of Florida appellate rulings confronting the consequences of artificial intelligence-generated legal research.

The underlying dispute arose from a foreclosure action brought by the Bank of New York Mellon against Samantha Roussell in Broward County’s Seventeenth Judicial Circuit. Roussell, proceeding pro se, appealed the circuit court’s ruling. In her appellate brief, however, she relied extensively on cases that the court determined were “hallucinated,” a term now widely used to describe fabricated outputs produced by generative AI tools. The Fourth DCA expressly disregarded these nonexistent authorities and affirmed the lower court’s decision without further discussion of the merits.

This decision is not the first time the Fourth DCA has addressed AI-generated citations. In Friend v. Serpa, the same court warned a pro se appellee who cited nonexistent cases that such “phantom authority” must be disregarded and that sanctions were available under the Florida Rules of Appellate Procedure.[ii] Earlier, in Goya v. Hayashida, the Fourth DCA found that a pro se party’s answer brief was “replete with and entirely supported by fake cases and legal propositions, presumably generated by artificial intelligence.”[iii] Taken together, these decisions reflect the Fourth DCA’s increasing frustration with litigants who submit AI-generated authority without verifying its accuracy.

The problem of AI hallucinations in legal filings extends well beyond Florida. The issue first gained national attention in 2023 when a federal judge in the Southern District of New York sanctioned two attorneys in Mata v. Avianca, Inc. for submitting a brief that cited entirely fictitious cases generated by ChatGPT.[iv] Since then, courts across the country have encountered similar filings from both attorneys and pro se litigants who failed to verify AI-generated outputs. In response, the Florida Bar issued Ethics Opinion 24-1 in January 2024, confirming that lawyers may use generative AI but emphasizing that they remain fully responsible for the accuracy and competence of all submissions to the court.[v]

What makes Roussell particularly notable is the sheer scope of the inaccurate citations. The court identified thirteen wholly fabricated cases and nine real cases cited for propositions they do not support, totaling twenty-two deficient citations in a single brief. The court emphasized that any party, whether represented by counsel or proceeding pro se, bears responsibility for the content of submissions to the court. While the panel declined to impose sanctions, it expressly noted its authority to do so under Florida Rule of Appellate Procedure 9.410(a) for noncompliance with Rule 9.210(c), which governs the content and form of appellate briefs.[vi]

For Florida practitioners, Roussell signals that the Fourth DCA’s patience with AI-fabricated authority is wearing thin. Each successive opinion, from Goya to Friend to Roussell, has included progressively sterner warnings. The court’s repeated reminders that sanctions remain available suggest that future litigants who submit hallucinated citations may not receive the same leniency. As generative AI tools become more accessible, both attorneys and self-represented parties must treat their outputs as a starting point for research, not a substitute for it. The obligation to verify every citation remains squarely on the individual who signs the brief.

[i] Roussell v. Bank of N.Y. Mellon, No. 4D2025-1309, 2026 WL 681054, at *1 (Fla. 4th DCA Mar. 11, 2026).

[ii] Friend v. Serpa, 425 So. 3d 51, 51 (Fla. Dist. Ct. App. 2025).

[iii] Goya v. Hayashida, 418 So. 3d 652, 656 (Fla. Dist. Ct. App. 2025).

[iv] Mata v. Avianca, Inc., 678 F. Supp. 3d 443, 448 (S.D.N.Y. 2023).

[v] Fla. Bar Ethics Op. 24-1 (Jan. 19, 2024).

[vi] Fla. R. App. P. 9.410(a); see also Fla. R. App. P. 9.210(c).

A recent Eleventh Circuit dispute addresses the ongoing tension between state immigration enforcement efforts and the federal government’s constitutional authority over immigration policy. The litigation centers on Florida’s Senate Bill 4-C (SB 4-C), a bill proposal enacted during a special legislative session that created new state crimes targeting certain undocumented immigrants who enter Florida after entering the United States without federal inspection or after prior removal.[i] Shortly after the law’s enactment, immigrant advocacy organizations and individual plaintiffs filed suit in the United States District Court for the Southern District of Florida against Attorney General James Uthmeier.[ii] More specifically, Florida Immigrant Coalition (FLIC) and the Farmworker Association of Florida (FWAF), along with two individuals, are the named plaintiffs in this case.[iii]

The central issue that the Eleventh Circuit will eventually decide is whether Florida’s statute intrudes upon a field that Congress has already occupied. The plaintiffs argued that SB 4-C violates the Supremacy Clause because immigration regulation falls primarily within the federal government’s authority.[iv] At the same time, Florida contends that states retain the authority to enact laws to deter unlawful entry into their territories. Plaintiffs argued that the Immigration and Nationality Act already governed as it regulated the entry, presence, and removal of noncitizens. This act leaves little room for states to create independent immigration crimes, meaning SB 4-C improperly creates a parallel state immigration offense that conflicts with the federal framework.

The Southern District Court of Florida agreed that the plaintiffs were likely to succeed on their constitutional claims and issued a preliminary injunction blocking enforcement of the statute while the case proceeds.[v] The court concluded that the law was likely preempted by federal immigration law because Congress had already created a detailed regulatory framework governing immigration enforcement.[vi] The district court also determined that the plaintiffs had standing to bring the lawsuit because they faced a credible threat of prosecution under the statute.

Florida appealed the injunction and asked the Eleventh Circuit to stay the district court’s order.[vii] A stay would allow the state to enforce the statute while the appellate court considers whether the district court correctly blocked the law. In reviewing the request, the Eleventh Circuit considered whether Florida demonstrated a likelihood of success on appeal and whether the balance of harms favored allowing the law to take effect. The Eleventh Circuit ultimately granted the state’s request for a stay of the injunction. As a result, the district court’s order preventing enforcement of SB 4-C has been temporarily suspended while the appeal moves forward. This procedural ruling allows Florida to enforce the statute during the pendency of the appeal, though the court has not yet resolved the underlying constitutional question concerning federal preemption.

While granting the order to stay, the Eleventh Circuit expedited the case to resolve the dispute more quickly. Although the Eleventh Circuit has not yet issued a final ruling on the Senate bill, the court’s stay order provides significant insight into its intentions. For now, the statute may be enforced while the appellate court evaluates the district court’s ruling.[viii] In July 2025, the United States Supreme Court ultimately denied Florida’s request to enforce its state immigration law.[ix] There was no dissenting opinion or explanation for the denial.[x] Their decision to deny the request follows a string of other decisions on laws similar to SB 4-C.[xi]

[i] See 2025 Fla. Sess. Law Serv. Ch. 2025-2 (S.B. 4-C) (West).

[ii] See Florida Immigrant Coalition, et. al v. James Uthmeier, et. al, 780 F. Supp. 3d 1235, 1251 (S.D. Fla. 2025).

[iii] See Federal Court Halts Florida’s Cruel Anti-Immigrant Law SB 4-C in Major Victory for Immigrant Justice, ACLU (Apr. 4, 2025, at 6:00 PM), https://www.aclu.org/press-releases/federal-court-halts-floridas-cruel-anti-immigrant-law-sb-4-c-in-major-victory-for-immigrant-justice (“The court ruled that the plaintiffs — including two individuals and two grassroots membership organizations, the Florida Immigrant Coalition (FLIC) and the Farmworker Association of Florida (FWAF) — are likely to succeed in showing that SB 4-C is unconstitutional.”).

[iv] See Florida Immigrant Coalition v. Uthmeier, ACLU (July 16, 2025), https://www.aclu.org/cases/florida-immigrant-coalition-v-uthmeier (“The court explained that ‘[i]t seems likely—given the federal government’s longstanding and distinct interest in’ immigration and Congress’s “extensive regulation” in this area—that SB 4C is preempted by federal law.”).

[v] See Federal Court Halts Florida’s Cruel Anti-Immigrant Law SB 4-C in Major Victory for Immigrant Justice, supra note iii.

[vi] See id.

[vii] See Florida Immigrant Coalition v. Uthmeier, supra note iv.

[viii] See id.

[ix] See U.S. Supreme Court Denies Florida’s Request to Enforce Unconstitutional Anti-Immigrant Law, ACLUFL (July 9, 2025, at 5:12 PM), https://www.aclufl.org/press-releases/u-s-supreme-court-denies-floridas-request-to-enforce-unconstitutional-anti-immigrant-law/.

[x] See id.

[xi] See id.

In Brown v. Fla. Health Sci. Ctr., Inc., the Second District Court of Appeals held that the trial court erred by not recognizing there were factual disputes that precluded summary judgment.[i] The trial court granted summary judgment to the respondent, Tampa General Hospital (TGH), because it found that petitioner Valerie Brown was a trespasser and therefore was not owed a duty of care by the hospital. [ii]

As Ms. Brown was bending over her father’s hospital bed, saying goodbye, all she remembers is being hit by the psychiatric patient who was sharing a room with her father.[iii] Ms. Brown was visiting her father, who was recovering from spinal surgery at TGH. The hospital placed a psychiatric patient, exhibiting hallucinations, agitation, erratic behavior, and noncompliance, in the same room as Ms. Brown’s father.[iv] The psychiatric patient repeatedly left his bed, ripped out his IV, and told staff that he was an emperor while jumping up and down on the bed.[v]  The psychiatric patient also screamed for Ms. Brown and her father to look at a dragon outside.[vi] He then ran out of the room and through the hallway, screaming, “fire!”[vii] The hospital staff also caught him wandering the halls, saying that he was looking for the “professor.”[viii] During this time, Ms. Brown’s father was bed-bound because of his spinal surgery, which caused Ms. Brown to be in fear for her father’s safety. She repeatedly expressed concerns to nurses, who refused to move either patient.[ix]

It is surprising that the trial court agreed with TGH that Ms. Brown was a trespasser, given that visitors are almost as vital to a hospital as its patients. When visiting someone in the hospital, the visitor is usually there because something medically serious has occurred. In the middle of the night, the visitor is there to offer support, love, prayer, and perhaps to crack a joke in an otherwise solemn setting. The visitor may have never been to a hospital before and could be scared by what they see: people being rolled around on beds, connected to tubes, rushing doctors, and crash carts whizzing by. Altogether, not a place that people choose to go on their day off. That being the case, a visitor is owed a standard duty of care as an invitee, not a trespasser. Visitors come bearing flowers, fruit baskets, balloons, get-well cards, and platters of food. If visitors were labeled as trespassers, it could negatively affect some very impactful people.

The trial court agreed with TGH’s position that because it was after visiting hours, Ms. Brown was a trespasser[x]. An invitee may become a trespasser “after the expiration of a reasonable time within which to accomplish the purpose for which [s]he is invited to enter, or to remain.”[xi] Ms. Brown’s status as a trespasser or invitee is bound up with material factual issues appropriate for jury resolution.[xii] Assuming that Ms. Brown was an invitee, we note that a property owner owes an invitee “the duty ‘to use reasonable care in maintaining property in a reasonably safe condition.’”[xiii] It’s clear that in this case, not only did the hospital have notice of the increasingly erratic behavior, but they acted with apathy towards Ms. Brown’s concerns. As a visitor, the hospital owed her a duty to ensure the conditions in which her father was being cared for were adequate.

The Second District Court of Appeals rightfully reversed the summary judgment and remanded the matter to the finder of fact. Whether Ms. Brown was a trespasser and whether the hospital owed her a duty of care are unresolved factual issues that preclude summary judgment for TGH and are better left to the jury.

[i] Brown v. Fla. Health Sci. Ctr., Inc., 51 Fla. L. Weekly 203 (Dist. Ct. App. 2026).

[ii] Id. at 12.

[iii] Id. at 4.

[iv] Id. at 1.

[v] Id. at 2.

[vi] Id. at 3.

[vii] Id.

[viii] Id. at 2.

[ix] Id.

[x] Id. at 6.

[xi] Byers v. Radiant Grp., L.L.C., 966 So. 2d 506, 509 (Fla. Dist. Ct. App. 2007) (quoting Restatement (Second) of Torts, § 61 at 425).

[xii] Brown v. Fla. Health Sci. Ctr., Inc., 51 Fla. L. Weekly 203, 9 (Dist. Ct. App. 2026).

[xiii] Ruiz v. Wendy’s Trucking, LLC, 357 So. 3d 292, 301 (Fla. 2d DCA 2023).

One credential quietly determined whether a law graduate could even attempt to become a Florida lawyer: graduate from a law school accredited by the American Bar Association (“ABA”). In April 1950, the Florida Supreme Court created the Florida Bar, uniting all licensed attorneys in the state into one organization, responsible for regulations.[i] The Florida Supreme Court’s order shifted the responsibility of disciplinary actions from local state attorneys to a Board of Governors consisting of fourteen special committees.[ii] In 1992, the ABA became the sole law school accreditor recognized in the Court, and the rules have relied on this accreditation since 1955.[iii] Due to the integration, rule 4-13.2 established that “an accredited law school is one approved or provisionally approved by the ABA at the time of, or within twelve months of, the applicant’s graduation.”[iv]

This requirement changed in January 2026, when the Florida Supreme Court amended its bar admission rules to end the ABA’s status as the sole accrediting gatekeeper.[v] The decision came after the Court appointed a workgroup to inquire on the issue in March 2025.[vi] Thus, based on that study, the Court decided it was not in Florida’s best interest for the ABA to continue to monopolize who is allowed to sit for the Bar Exam to earn their license to practice.[vii]

Under the amended rules, it “. . . promote[s] access to high-quality, affordable legal education in law schools that are committed to the free exchange of ideas and to the principle of nondiscrimination.”[viii] Florida continues to recognize graduates of ABA-accredited schools, but it also allows graduates of law schools accredited by other entities. The decision was possible because it was within the Court’s constitutional authority, “[t]he supreme court shall have exclusive jurisdiction to regulate the admission of persons to the practice of law and the discipline of persons admitted.”[ix] The decision raises an important question for the legal profession: whether expanding accreditation pathways will meaningfully improve access to legal education without sacrificing quality? This decision reflects a deliberate move away from a single national standard toward a more flexible regulatory framework.

The opinion emphasizes that this change is not a rejection of ABA-accreditation, rather, the Court frames its decision as a recalibration of authority. The new framework expands the definition of “accredited” to no longer exclusively correlate to the ABA.[x] The expanding on the amendment has two separate frameworks. First, it allows accreditation by any “programmatic accrediting agency recognized by the United States Department of Education to accredit programs in legal education that lead to the first professional degree in law.”[xi] Which is currently a category that only includes the ABA. Second, it permits accreditation by institutional accrediting agencies, provided those agencies are both federally recognized and approved by the Court.[xii] The latter option gives Florida the ability to impose its own conditions focused on outcomes, such as bar passage rates, employment disclosures, and curricular standards.[xiii]

For instance, the majority’s reasoning reflects concern about cost and access. Law school tuition is constantly increasing, and critics of the ABA accreditation process have long argued that compliance costs contribute to rising student debt. The United States Federal Trade Commission has called out the ABA for being a monopoly because it has increased the cost of earning a law degree, hindering the reservoir of new lawyers.[xiv] The ABA has historically been the only recognized law school accreditation in the nation, allowing for there to be only one distinct policy to adhere to.

However, Justice Labarga’s dissent highlights the risks inherent in departing from such a long-standing system.[xv] He emphasizes that the ABA has served as Florida’s sole accreditor since 1992 and has developed extensive expertise in evaluating legal education quality.[xvi] Justice Labarga also argues that the ABA standards provide consumer protection, transparency, and institutional accountability, features that may take years for any alternative accreditor to replicate.[xvii] The history behind the organization is a rather strong front, and this change will most likely not immediately pan out.

Nevertheless, the Court’s decision does not immediately transform Florida’s legal educational environment as the amendments take effect on October 1, 2026. Graduates of ABA-accredited schools remain fully eligible to sit for the Bar; the ruling creates a potential change rather than an immediate one, allowing for the proper development of the amendments. Whether this shift ultimately benefits aspiring lawyers and the public will depend on implementation. Texas and Florida stand as the catalysts for this movement, which can possibly lead to the erasure of the ABA’s monopoly on the law school atmosphere.

[i] Mark D. Killian & Samadhi Jones, The Florida Bar Timeline 1950–2025, Fla. Bar (Sep. 8, 2025), https://www.floridabar.org/the-florida-bar-news/the-florida-bar-timeline-1950-2025 (“In April 1950, the Florida Supreme Court entered an order officially creating The Florida Bar as an integrated (mandatory) bar, uniting all licensed attorneys in the state into a single professional organization responsible for regulating the practice of law.”).

[ii] Id.

[iii] See In Re Amends. to Rules Regulating Fla. Bar & Rules of Sup. Ct. Relating to Admissions to Bar, 51 Fla. L. Weekly 25 (2026).

[iv] Id.

[v] See id.; see also Liv Caputo, Florida Supreme Court Ends Three-Decade Reliance on ABA, Handing Win to DeSantis, Fla. Phoenix (Jan. 15, 2026, at 12:43 PM), https://floridaphoenix.com/2026/01/15/florida-supreme-court-ends-three-decade-reliance-on-aba-handing-win-to-desantis/.

[vi] See In Re Amends. to Rules Regulating Fla. Bar & Rules of Sup. Ct. Relating to Admissions to Bar, supra note iii.

[vii] See id.

[viii] Id.

[ix] Fla. Const. art. V, § 15.

[x] In Re Amends. to Rules Regulating Fla. Bar & Rules of Sup. Ct. Relating to Admissions to Bar, supra note iii.

[xi] Id.

[xii] Id.

[xiii] See id.

[xiv] See Chris Williams, FTC Blames High Law School Costs on ABA Accreditation, Above Law (Dec. 3, 2025, at 4:55 PM), https://abovethelaw.com/2025/12/ftc-blames-high-law-school-costs-on-aba-accreditation/.

[xv] See In Re Amends. to Rules Regulating Fla. Bar & Rules of Sup. Ct. Relating to Admissions to Bar, 51 Fla. L. Weekly 25 (2026) (Labarga, J., dissenting).

[xvi] See id.

[xvii] Id.

In the prominent world of Name, Image, and Likeness (“NIL”) in collegiate athletics, the National Collegiate Athletic Association (“NCAA”) has been involved in their fair share of litigation surrounding athletes requesting additional years of eligibility.  The most notable instance of the NCAA involved in litigation is against Trinidad Chambliss, the quarterback who led the University of Mississippi (“Ole Miss”) to their first College Football Playoff appearance in 2025-2026.[i]  Just a month ago, Chambliss was granted a favorable ruling by a trial court in Mississippi.[ii] But the NCAA is not only litigating claims against prominent athletes like Chambliss.

On March 6, 2026, Florida’s Fifth District Court of Appeal reversed the issuance of a preliminary injunction to Doctor Bradley (“Bradley”), a member of Bethune-Cookman University’s (“BCU”) basketball program.[iii]  BCU is the sixth university which Bradley has been enrolled in.[iv]  The most important information from these six years comes from Bradley’s penultimate college stop, as this is where the litigation against the NCAA stems from. While at Nicholls State University (“Nicholls State”) during the 2023-2024 season, Bradley opted to step away from the team amidst legal troubles he faced due to his involvement in a hazing incident at New Mexico State University (“NMSU”), the school he attended prior to Nicholls State.[v]  In a waiver filed to the NCAA by BCU on Bradley’s behalf, the school requested Bradley be granted an additional year of eligibility in part because he was denied an opportunity to play in the 2023-2024 season with Nicholls State due to circumstances beyond his own control.[vi] These circumstances were in reference to the hazing incident that Bradley was involved in.

The NCAA would deny the waiver request by finding there was no objective documentation that Bradley could not compete at Nicholls State for reasons that were beyond his control.[vii] The NCAA on reconsideration would further find that the 2023-2024 season was not a denied participation opportunity because Bradley decided himself to step away from the team, partially due to pending legal matters connected to the hazing incident.[viii] BCU would choose not to pursue any further appeals, and instead, Bradley would file a complaint against the NCAA.[ix] Bradley alleged that the NCAA was violating the Florida Antitrust Act by denying him a waiver to play with BCU, and sought to enjoin the NCAA from violating the Act.[x] Bradley also sought an order from the court declaring that he is entitled to play basketball for BCU for the 2025-2026 season.[xi]

The court below would grant Bradley’s temporary injunction on January 9, 2026, allowing him to join BCU for the remainder of the season.[xii] One of the main issues, according to the Fifth District, is that the lower court provided only a short two-paragraph analysis as to why Bradley was entitled to a temporary injunction.[xiii] The Fifth District noted the four elements necessary to establish a temporary injunction is warranted. They also provided Florida case law that states that a trial court must give clear, definite, and unequivocal sufficient factual findings to support each of the four elements.[xiv] The trial court’s two-paragraph analysis was obviously deficient to justify a temporary injunction, a remedy that is to be issued only in rare circumstances.[xv] The trail court’s order fell short due to its lack of sufficient factual findings for three of the temporary injunction elements while completely omitting to mention one of the elements entirely. Also mentioned was the fact that Bradley alleged a violation of the Florida Antitrust Act, a case that would be fact-intensive and surely garner more than two paragraphs of conclusory analysis.

This kind of favorable ruling for Bradley could spark an interesting conversation in that athletes may get more favorable rulings with local state court judges. For example, the previously mentioned Chambliss received a favorable ruling allowing him to play in a sixth year of college football after previously being denied additional eligibility. The judge who presides over Chambliss’ case, Judge Robert Whitwell, graduated from Ole Miss law,[xvi] and it could be argued that he subjectively might like to see Chambliss back with the Rebels because of his athletic abilities. In fact, Chambliss’ lawyers likely strategically filed in Mississippi state court.[xvii] There is no indication that the judge presiding over Bradley’s case, Judge Dennis Craig, is affiliated with BCU in any way. However, it could be argued that he would want to possibly see his local Division I college basketball team benefit from a veteran like Bradley playing. Issuing a conclusory and fact deficient order granted a precious remedy like a temporary injunction certainly can serve as circumstantial evidence that the filing in state courts is much more favorable to the college athletes and the NCAA would have to rely on the appellate court to correct orders such as the one entered in Bradley’s case.

[i] Pete Thamel, Ole Miss QB Trinidad Chambliss granted injunction for 2026, ESPN (Feb. 12, 2026 6:18 ET), https://www.espn.com/college-football/story/_/id/47912898/ole-miss-qb-trinidad-chambliss-granted-injunction-judge.

[ii] Id.

[iii] See Nat’l Collegiate Athletic Ass’n v. Bradley, No. 5D2026-0128, slip op. at 2 (Fla. 5th DCA Mar. 6, 2026).

[iv] Id.

[v] Id. (“Nicholls State University . . . where he transferred during the 2023-2024 season until Bradley left the team due to complications stemming from the hazing incident at NMSU”).

[vi] Id. at 3.

[vii] Id. at 4.

[viii] Id. at 4.

[ix] Bradley, slip op. at 4.

[x] Id.

[xi] Id.

[xii] Id.

[xiii] Id. at 4–5.

[xiv] See Fla. R. Civ. P. 1.610; see also Wayne’s Aggregate & Materials, LLC v. Lopez, 391 So. 3d 633, 636 (Fla. 5th DCA 2024).

[xv] See Bradley, slip op. at 6; see also Blue Earth Sols. V. Fla. Consol. Props., LLC, 113 So. 3d 991, 992 (Fla. 5th DCA 2013) (“A mandatory injunction should be issued in only the rarest of circumstances where the rights are clear and certain.”).

[xvi] Caleb Salers, Attorneys representing Ole Miss QB Chambliss sue NCAA for sixth year of eligibility, Super Talk Miss. Media (Jan. 16, 2026), https://www.supertalk.fm/attorneys-representing-ole-miss-qb-chambliss-sue-ncaa-for-sixth-year-of-eligibility/ (“The judge overseeing Chambliss’ case is Senatobia native Robert Whitwell, an Ole Miss Law graduate and former Northwest Mississippi Community College Quarterback.”).

[xvii] Thamel, supra note 1 (“The case was heard in a state court, which was a strategic decision by Chambliss’ lawyers when they filed for the injunction last month.”).