The Grandview Palace Condominium Association, Inc. v. Judge, Case No. 3D25-0458. (Fla. 3d DCA 2026).
A trial court properly directs a verdict for the defendant in a breach-of-contract action when the plaintiff's proof of causation would require the jury to stack an unproven initial inference upon further inferences rather than establishing the underlying fact to the exclusion of all other reasonable inferences.
Zorella v. Pathman Schermer Tandy, LLP, Case No. 3D25-1443 (Fla. 3d DCA 2026).
The lodestar method of Florida Patient's Compensation Fund v. Rowe does not govern the assessment of damages for breach of an agreement to pay attorney's fees where the disputed fee is to be paid by the client rather than by a non-client payor.
Gleason v. IFP Development, LLC, Case No. 5D2024-2974. (Fla. 5th DCA 2026).
Where a settlement agreement expressly contemplates (but does not require consummation of) a contingency such as a possible purchase of real property and the settling party retains other consideration under the agreement's plain terms, the agreement is not rendered unenforceable for failure of consideration merely because the contemplated component of the bargain is not consummated.
Northwest Baptist Church of Cocoa, Inc. v. Trustee Corp. of the King Street Baptist Church, Inc., Case No. 5D2025-0272. (Fla. 5th DCA 2026).
A grantor church that conveys property by warranty deed containing a reverter clause naming other specific successor entities without any provision for reversion to the grantor retains no ownership, possessory, or reversionary interest in the property and therefore lacks standing to sue regarding that property.
Atout v. Rozanc, Case No. 6D2023-2302. (Fla. 6th DCA 2026).
A property management agreement obligating a manager to "manage, operate and lease" property is breached when the manager instead sells the property without authorization, and a negligence claim against a contracting party or its employee is barred as impermissibly "dependent" on the contract – rather than an "independent" tort – where the source of the duty, the nature of the conduct, the nature of the damages, and public policy all indicate the claim merely recasts the contractual breach with corporate employees who perform the contract on the corporation's behalf sharing the same protection from such dependent tort claims as the corporation itself.
