Construction defect litigation in Florida has long existed in tension between a claimant’s right to seek judicial relief and the Legislature’s directive that parties first attempt to resolve disputes without the courts. Chapter 558 of the Florida Statutes embodies that directive, requiring claimants to serve written pre-suit notice on contractors before initiating litigation for construction defects. A recent decision from the Third District Court of Appeal confirms that this requirement is not merely procedural guidance; it is a mandatory condition precedent that courts may not overlook.[i]

In early 2024, Daystar Peterson (“Peterson”), a condominium unit owner at Brickell Heights East (“Brickell Heights”), in Miami, filed suit in the Circuit Court for Miami-Dade County against the condominium association and Moss & Associates, LLC (“Moss”).[ii] Moss was a general contractor hired by the association to perform renovations and repairs to the building.[iii] Peterson alleged that Moss’s negligent workmanship caused water damage to his unit.[iv] Critically, Peterson did not serve Moss with any written notice of claim before filing suit.[v]

Section 558.004, Florida Statutes, mandates that a claimant serve written notice on a contractor at least sixty days before filing a construction defect action or one hundred twenty days when the action involves an association representing more than twenty parcels.[vi] Peterson did not dispute that he had failed to serve the required notice; instead, he argued that he could not have done so because he was unaware of the specific details of Moss’s scope of work.[vii] Moss moved to stay the litigation under section 558.003, which provides that when a claimant files a construction defect action without first satisfying Chapter 558’s requirements, the court “shall stay the action, without prejudice.”[viii] The trial court denied Moss’s motion, characterizing it as “premature” and suggesting the issue could be revisited at a later stage of the proceedings.[ix] Moss then petitioned the Third District Court of Appeal for a writ of certiorari.[x]

To obtain certiorari relief, a petitioner must demonstrate (1) irreparable harm that cannot be remedied on appeal, and (2) a departure from the essential requirements of the law.[xi] On irreparable harm, the court drew a direct analogy to an insured’s failure to comply with the pre-suit notice requirements of section 627.70152, Florida Statutes.[xii] The court reasoned that once litigation proceeds without the required Chapter 558 notice, the opportunity for confidential pre-suit settlement negotiations is permanently lost, which is an injury that no appellate ruling can undo.[xiii] Post-judgment appeal cannot restore the statutory process the Legislature designed to resolve claims without litigation.

On departure from essential requirements, the court emphasized that section 558.003’s use of the word “shall” strips the trial court of any discretion.[xiv] When a claimant files a construction defect action without Chapter 558 compliance, the statute mandates a stay. By denying Moss’s timely motion, the trial court failed to apply plain, unambiguous statutory language and thereby departed from the essential requirements of the law. The Third DCA granted the petition and quashed the trial court’s order.[xv]

Moss & Associates, LLC v. Peterson carries significant practical consequences. For claimants, it eliminates any argument that Chapter 558 notice requirements can be deferred or excused simply because a claimant is unfamiliar with a contractor’s scope of work. The statute requires notice based on at least a visual inspection and a reasonable description of each alleged defect—not a full forensic investigation. For contractors and their counsel, this decision provides a clear and enforceable procedural remedy. A complete absence of any Chapter 558 notice is sufficient grounds for certiorari review, not merely a defense to raise at trial. Ultimately, this ruling reinforces the Legislature’s intent behind Chapter 558: to encourage resolution of construction defect claims through confidential settlement negotiations before resorting to litigation. Courts must enforce that intent, and parties cannot circumvent it by filing suit first and expecting the pre-suit process to be overlooked.

[i] See Moss & Associates, LLC v. Peterson, 406 So. 3d 344, 346 (Fla. 3d DCA 2025).

[ii] See id.

[iii] See id.

[iv] See id.

[v] See id.

[vi] See Fla. Stat. § 558.004 (1)(a) (2025).

[vii] See Moss & Associates, 406 So. 3d at 348.

[viii] See id.

[ix] See id.

[x] See id.

[xi] See Thomas-McDonald Law Firm, P.A. v. Silva, 400 So. 3d 753 (Fla. 3d DCA 2024).

[xii] See Moss & Associates, 406 So. 3d at 349.

[xiii] See id.

[xiv] See id.

[xv] See id.

Judicial impartiality is essential to the legitimacy of the legal system, and Florida law requires judges to step aside when a litigant reasonably fears that neutrality has been compromised. Under Florida Rule of General Practice and Judicial Administration 2.330, a party may move to disqualify a judge when the alleged facts would place a reasonably prudent person in fear of not receiving a fair and impartial trial.[i] Importantly, the rule does not require proof that the judge is actually biased. Instead, the focus is on whether the circumstances create a reasonable perception of partiality. This emphasis reflects a foundational principle of judicial ethics: the judiciary must preserve not only fairness itself, but the public’s confidence that justice is administered impartially.

Florida’s disqualification doctrine therefore rests on an objective standard designed to protect litigants from the appearance of judicial bias. In MacKenzie v. Super Kids Bargain Store, Inc., the Florida Supreme Court explained that the relevant inquiry is whether the facts alleged would cause a reasonably prudent person to fear that they could not receive a fair trial.[ii] Courts evaluating a motion for disqualification do not determine whether the allegations are true. Instead, they assess only whether the motion is legally sufficient to create a reasonable fear of partiality. If that threshold is met, recusal becomes mandatory. This procedural posture protects litigants from the nearly impossible burden of proving actual bias while ensuring that judicial neutrality remains beyond reasonable doubt.

Recent refinements to Rule 2.330 clarify the procedural requirements governing judicial disqualification and reinforce the rule’s protective function. The rule requires that a motion set forth the specific facts supporting disqualification and identify the date the moving party discovered those facts.[iii] In addition, litigants generally have twenty days after discovering the grounds for disqualification to file the motion.[iv] Perhaps most importantly, the rule confirms that the challenged judge may determine only the legal sufficiency of the motion, not the truth of the allegations. When a motion is legally sufficient, the judge must enter an order granting disqualification and take no further action in the case. These procedural safeguards ensure that disputes over impartiality are resolved quickly and transparently.

Florida Appellate Courts have consistently reinforced this objective framework when reviewing disqualification issues. In Fischer v. Knuck, the Florida Supreme Court emphasized the procedural limits of disqualification, making clear that a motion filed after an adverse ruling is legally insufficient and cannot be used as a strategic tool to challenge the court’s decision.[v] By focusing on the legal sufficiency of the motion rather than the judge’s subjective view, the doctrine prioritizes the integrity of the judicial process over individual judicial discretion.

Judicial comments or conduct during proceedings can also create grounds for recusal when they suggest hostility or a predetermined view of the case. In Livingston v. State, the Florida Supreme Court recognized that judicial remarks demonstrating antagonism that would cause a reasonable fear of unfairness in the proceeding may require disqualification.[vi] Although judges inevitably approach disputes with their own experiences and perspectives, the law requires that those perspectives never interfere with the impartial administration of justice.

The relationship between perception and fairness in the courtroom can be understood through a useful artistic analogy. In visual art, the canvas may change from one work to the next, but the frame must remain level to present the image clearly. Litigation presents a similar dynamic. Each case introduces new facts, arguments, and narratives, the “art” placed before the court. But the structural rules of procedure operate as the frame, ensuring that the adjudicative process remains balanced regardless of the dispute being considered. Judicial disqualification doctrine functions as part of that structural frame, preventing even the appearance that personal perspective has tilted the judicial process.

Ultimately, Florida’s disqualification framework protects not only individual litigants but also the institutional legitimacy of the judiciary itself. When judges step aside in cases that raise reasonable concerns about impartiality, they reaffirm the legal system’s commitment to fairness and transparency. In doing so, they reinforce a foundational principle of justice: courts must not only administer the law fairly but must also maintain the public’s confidence that they are doing so.

[i] Fla. R. Gen. Prac. & Jud. Admin. 2.330 (2026).

[ii] MacKenzie v. Super Kids Bargain Store, Inc., 565 So. 2d 1332, 1335 (Fla. 1990).

[iii] Fla. R. Gen. Prac. & Jud. Admin. 2.330(c) (2026).

[iv] Fla. R. Gen. Prac. & Jud. Admin. 2.330(g) (2026).

[v] Fischer v. Knuck, 497 So. 2d 240, 242–43 (Fla. 1986).

[vi] Livingston v. State, 441 So. 2d 1083, 1085–86 (Fla. 1983).

When does a barn stop being part of a farm and become something else entirely? That is the central question in Florida’s Second District Court of Appeal’s decision in Sheik Island Farm, Inc. v. Covington Farm, Inc. The court framed the issue succinctly at the outset of its opinion: “Is renting out a barn for weddings the same thing as operating a farm?”[i] The decision boiled down to the meaning of one common word – “farm” – and that determination is a factual one to be decided by a jury.

Florida’s Right to Farm Act, section 823.14, Florida Statutes, was enacted to protect legitimate agricultural operations from nuisance claims as urban development expands into rural areas. [ii] The statute generally prevents farms that comply with accepted agricultural practices from being held liable for nuisance, provided the operation has existed for more than one year and follows environmental regulations and best management practices.[iii]

The dispute in Sheik Island Farm arose between neighboring properties in Pasco County. Sheik Island Farm operated a horse-boarding business along Covington Road in Dade City. In 2016, a nearby property was purchased by James and Barbara Stalnaker, who later developed what became known as Covington Farm. Although the property was classified as agricultural for tax purposes, the Stalnakars constructed a large barn and began using the property primarily as a wedding and event venue.

Sheik Island Farm alleged that the venue created significant disturbances for its horse-boarding operation. Increased traffic, speeding vehicles, dust from the dirt road, and garbage from events interfered with the farm’s use of its property and affected the horses. The farm filed suit asserting claims for private nuisance, public nuisance, and violation of the Pasco County Land Development Code.

The trial court granted summary judgment in favor of Covington Farm. The court reasoned that because the property had been classified as agricultural under Florida’s “greenbelt” tax statute, the Florida Right to Farm Act barred the nuisance claims and exempted the property from certain local regulations.[iv]

The Second District Court of Appeal disagreed. The court explained that the Right to Farm Act protects only properties that actually qualify as “farms” under the statute.[v] The Act defines a farm as land and facilities used in the production of farm products, which includes plants, animals, or insects useful to humans.[vi] Because the statute focuses on agricultural production, the key issue was whether Covington Farm’s property was actually being used as a farm.

Applying the plain language of the statute, the court emphasized that the key inquiry was how the property was actually being used. The record contained sufficient evidence suggesting the property functioned primarily as a commercial wedding venue rather than a farming operation. Marketing materials, tax filings, and testimony indicated that the property generated revenue through event rentals rather than agricultural production. Because a reasonable jury could conclude that the property was not operating as a farm, the court held that summary judgment was improper.

The court also rejected the trial court’s reliance on the property’s agricultural tax classification. While that designation may serve as evidence of agricultural use, it exists primarily for ad valorem tax purposes and does not automatically determine whether property qualifies as a farm under the Right to Farm Act. The statutes governing agricultural tax classification and nuisance protections serve different purposes, and one does not control the other.

The Second District ultimately reversed the summary judgment and remanded the case for further proceedings. The decision underscores that statutory protections for agriculture depend not simply on how property is labeled, but on how it is actually used.

As agritourism and rural event venues continue to expand across Florida, disputes like this one are likely to become more common. Sheik Island Farm, Inc. v. Covington Farm, Inc. signals that courts will look beyond marketing labels and tax classifications when determining whether a property qualifies for the protections of the Right to Farm Act. In other words, simply hosting events in a barn on agricultural land does not automatically transform a wedding venue into a farm.

[i] Sheik Island Farm, Inc. v. Covington Farm, Inc., No. 2D2025-0151, 2026 WL 517611, at *1 (Fla. 2d DCA Feb. 25, 2026).

[ii] Fla. Stat. § 823.14 (2022).

[iii] Fla. Stat. § 823.14(4) (2022).

[iv] Fla. Stat. § 193.461(1) (2025).

[v] Sheik Island Farm, Inc., No. 2D2025-0151, 2026 WL 517611, at *4.

[vi] Fla. Stat. § 823.14(3)(c) (2022); see Fla. Stat. § 570.86(1) (2025) (defining “agritourism activity”).

In United States v. Ragland, the United States Court of Appeals for the Eleventh Circuit addressed whether a defendant resentenced after the vacatur of a firearm conviction may benefit from the sentencing reforms enacted in the First Step Act.[i]  The case highlights how recent Supreme Court precedent continues to reshape federal sentencing law, particularly for defendants who received lengthy sentences under the former “stacking” framework of 18 U.S.C. § 924(c).

Michael Shane Ragland was convicted in 2009 for his role in a series of armed robberies of Florida convenience stores. A federal jury found him guilty of eighteen counts, including multiple violations of § 924(c), which criminalizes using or brandishing a firearm during a crime of violence. At the time of Ragland’s sentencing, § 924(c) contained a stacking mechanism that imposed increasingly severe mandatory minimum sentences for multiple firearm convictions charged in the same indictment. After a defendant’s first § 924(c) conviction, each additional conviction carried a mandatory minimum sentence of twenty-five years to be served consecutively. As a result of this structure, Ragland received a sentence totaling 196 years in federal prison.

In the years following his conviction, developments in Supreme Court precedent created new opportunities for defendants to challenge firearm convictions predicated on certain offenses. Ragland sought relief through a motion under 28 U.S.C. § 2255, relying on United States v. Taylor, in which the Supreme Court held that attempted Hobbs Act robbery does not qualify as a “crime of violence” for purposes of § 924(c).[ii] Because one of Ragland’s firearm convictions was predicated on attempted Hobbs Act robbery, the district court vacated that count and ordered resentencing.

At resentencing, Ragland argued that the district court should apply the First Step Act of 2018.[iii]  The Act significantly altered § 924(c)’s sentencing framework by eliminating the automatic stacking of twenty-five-year mandatory minimum sentences when multiple firearm charges are brought in the same case. Instead, the enhanced penalty now applies only when a defendant commits a new § 924(c) offense after a prior conviction has become final. The district court declined to apply the First Step Act and resentenced Ragland to 173 years in prison.

Ragland appealed, and the Eleventh Circuit initially affirmed the district court’s decision based on its prior precedent interpreting the First Step Act’s retroactivity. However, only two days after the panel issued its opinion, the Supreme Court decided Hewitt v. United States.[iv]  In Hewitt, the Court held that defendants who appear for sentencing after the enactment of the First Step Act, including those whose earlier sentences were vacated, are subject to the Act’s revised sentencing provisions.[v]

In light of Hewitt, the Eleventh Circuit granted Ragland’s petition for rehearing.[vi]  The court concluded that because Ragland’s sentence had been vacated and he appeared before the district court for a new sentencing proceeding, the First Step Act’s revised penalties applied. The Court therefore vacated Ragland’s sentence and remanded the case for resentencing consistent with the Act.

The court also rejected Ragland’s attempt to expand his § 2255 motion to challenge additional firearm convictions. The Eleventh Circuit held that district courts lack jurisdiction to consider claims beyond those authorized by the court of appeals in a successive § 2255 motion. In doing so, the court declined to follow approaches adopted by other circuits that allow broader amendments to post-conviction petitions.

The decision in Ragland reflects the continuing impact of both legislative reform and Supreme Court intervention on federal sentencing. By applying the Supreme Court’s guidance in Hewitt, the Eleventh Circuit confirmed that defendants whose sentences are vacated and reconsidered after the First Step Act may benefit from Congress’s effort to reduce the harsh consequences of § 924(c) stacking.

[i] See United States v. Ragland, No. 23-12278, 2025 WL 1742251, 2 (11th Cir. Mar. 5, 2026).

[ii] See United States v. Taylor, 596 U.S. 824, 1-3 (2022).

[iii] See First Step Act of 2018, Pub. L. No. 115-391, § 403, 132 Stat. 5194, 5221-22 (2018).

[iv] See Hewitt v. United States, 145 S. Ct. 2165, 1 (2025).

[v] See First Step Act of 2018, supra note iii. 

[vi] See Hewitt, 145 S. Ct. at 2-3; see also Ragland No. 23-12278 at 1.

Recently, in City of Tampa v. Liberty Hospitality Management, LLC, Florida’s Second District Court of Appeal, discussed an unusual issue in a rezoning dispute. The question before the court was: whether a circuit court has jurisdiction to review a municipal rezoning decision when a city council acts in a quasi-judicial capacity. The answer, according to the Second District, is a resounding yes for one simple yet well-established reason, Florida’s constitutional separation-of-powers clause does not apply to local governments.[i]

The dispute arose when Liberty Hospitality Management’s attempt to rezone property on Harbour Island in Tampa to allow development of a hotel. Their objective was to increase the island’s hotel entitlements by 150 rooms and 160 parking spaces allocated to the project. After conducting a public hearing, the Tampa City Council denied the rezoning request, which resulted in Liberty seeking review in circuit court via the filing of a petition for a writ of certiorari challenging the City Council’s decision.[ii]

Rather than addressing the merits of the rezoning decision, the circuit court dismissed the petition for lack of jurisdiction. The court reasoned that because the Tampa City Council is part of the legislative branch of municipal government, it could not exercise quasi-judicial authority unless the Florida Constitution expressly allowed it. Following that reasoning, the court concluded that Florida’s separation-of-powers clause prevented the City Council from engaging in quasi-judicial decision making and therefore prevented the circuit court from reviewing the decision through certiorari.[iii]

The Second District vehemently disagreed.

Writing for the court, Judge Morris opined that the circuit court’s analysis began with a fundamentally flawed premise. Article II, Section 3 of the Florida Constitution, divides the state government into legislative, executive, and judicial branches.[iv] However, Florida courts have long recognized and held that this separation-of-powers pertains to the structure of the state government, not local government entities such as counties and municipalities.

Cities, the court noted, are creatures of the state without independent sovereignty. Because of that status, the constitutional separation-of-powers framework that governs the three branches of state government does not operate at the municipal level in the same way.[v]

Once that flawed premise was removed, the rest of the circuit court’s jurisdictional reasoning collapsed.

            The Second District further explained that municipalities derive their authority from Article VIII, Section 2(b) of the Florida Constitution, which grants cities broad home-rule powers to conduct municipal government and exercise of powers for municipal purposes unless otherwise prohibited by law.[vi] Those powers include zoning authority and the ability to conduct hearings when evaluating development and rezoning applications.

            Under well-established Florida law, site-specific zoning decisions are considered quasi-judicial rather than purely legislative. When a decision affects identifiable parties, requires a hearing, and involves applying existing policy to specific facts, the action takes on a quasi-judicial character.[vii]

            That characterization matters because quasi-judicial decisions are subject to judicial review.

            When a local government acts in a quasi-judicial capacity, its decision may be reviewed in circuit court through a petition for writ of certiorari.[viii] Certiorari review allows courts to ensure that local governments provide procedural due process and base their decisions on competent substantial evidence.

            Because the Tampa City Council’s rezoning decision fit squarely within the aforementioned parameters, the circuit court had jurisdiction to review Liberty’s petition. By refusing to exercise that jurisdiction, the circuit court committed legal error.

            The Second District therefore granted the City’s petition for mandamus and directed the circuit court to consider Liberty’s certiorari petition challenging the rezoning decision.

            For practitioners, the case highlights the continuing importance of certiorari review in Florida land use litigation. Developers, property owners, and municipalities frequently litigate zoning disputes through the use of certiorari petitions, which ensures a limited yet critical mechanism for reviewing quasi-judicial local government decisions. Without that avenue of review, parties affected by site-specific zoning determinations would have little recourse to challenge procedural errors or evidentiary deficiencies in local decision making.

            More broadly, City of Tampa serves as a reminder that constitutional doctrines designed to structure the branches of state government do not automatically translate to the operations of local government. Municipal power in Florida derives largely from home-rule powers granted by the Florida Constitution and statutes, not from the rigid separation of powers framework that governs the state’s legislative, executive, and judicial branches.

            In other words, the separation of powers structure may keep Tallahassee in check, but it does not apply to city hall.

[i] City of Tampa v. Liberty Hospitality Mgmt., LLC, No. 2D2024-2082, 2026 WL 627977, at *6 (Fla. 2d DCA March 6, 2026)

[ii] Id.

[iii] Id.

[iv] Fla. Const. art. II, §3.

[v] Fried v. State, 355 So. 3d 899, 907 (Fla. 2023).

[vi] Fla Const. art. VIII, § 2(b).

[vii] Bd. of Cnty. Comm’rs v. Snyder, 627 So. 2d 469, 474 (Fla. 1993).

[viii] Fla. R. App. P. 9.030(c).

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.