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Volume XVIII, Issue 44

Nov. 12, 2025

 

Casa Express Corp. v. Bolivarian Republic of Venezuela, Case No. 24-11642 (11th Cir. 2025).

A district court lacks ancillary jurisdiction over supplementary proceedings seeking to impose constructive trust liability on third parties not already obligated to pay an existing judgment where the action is founded upon different facts and theories of liability than the original lawsuit.

 

Saadi v. Maroun, Case No. 22-11020 (11th Cir. 2025).

The Eleventh Circuit certifies questions to the Florida Supreme Court concerning whether money judgments are available under Florida Statute section 56.29(3)(b), whether fraudulently transferred funds must be identifiable under that provision, and whether 2014 and 2016 amendments to section 56.29 apply retroactively to claims accruing before enactment.

 

Carney v. City of Cape Coral, Case No. 1D2024-3084 (Fla. 1st DCA 2025).

An administrative law judge lacks jurisdiction to set a hearing on attorneys' fees when the movant fails to obtain a ruling before the ALJ relinquished jurisdiction to the agency and the agency declined to remand for fee proceedings.

 

Passco Cypress Creek DST v. Neidinger, Case No. 2D2024-1982 (Fla. 2d DCA 2025).

A landlord's counterclaim seeking unpaid prorated month-to-month rent and repair costs does not seek the same liquidated damages fee as the tenant's Florida Consumer Collection Practices Act claim; judgment on the pleadings is improper where the counterclaim raises distinct contractual theories not identical to the underlying FCCPA violation.

 

College Health II GP, Inc. v. Zahid, Case No. 3D24-2131 (Fla. 3d DCA 2025).

Summary judgment is properly denied where genuine disputes of material fact exist as to whether buyers breached a purchase and sale agreement by interfering with seller's ability to provide a marketable title at closing.

 

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Author

Manny Farach

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