The decisions
- The Waterfront in Naples Condominium Association, Inc. v. Reynolds Ventures, Inc. (6th DCA, August 21, 2026) — In the Sixth District, a timely trial de novo request identifying the award satisfies rule 1.820(h) without the words 'notice of rejection'; conflict certified with Third and Fourth Districts. Read it →
- Grace & Naeem Uddin, Inc. v. Miami-Dade County (3rd DCA, August 26, 2026) — Permissive 'wishes'/'may' protest language in a County contract creates no exhaustion requirement before suing for breach, and ambiguity is construed against the government drafter. Read it →
- The Cape FC, LLC v. Baker Barrios Architects, Inc. (M.D. Fla., August 24, 2026) — A federal trial court held a discovery-based accrual clause void under § 95.03 because it triggers earlier than § 95.11(b)'s certificate-based accrual. The ruling is persuasive, not binding. Read it →
The practical upshot
- Use rule 1.820(h)'s exact 'notice of rejection' language in trial de novo filings statewide. Sixth District leniency faces certified conflict and possible Supreme Court review.
- Before conceding exhaustion defenses on public contracts, check whether protest provisions use mandatory or permissive language, and file the entire agreement, not excerpts.
- Review AIA-style discovery accrual clauses in design contracts. One federal court found such a clause void under § 95.03 because it triggers earlier than § 95.11(b).
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