James Gorfin v. Frederick William Hall, Woodside Credit, LLC, et al.
The Fourth DCA reversed a non-final order granting partial summary judgment that awarded a buyer immediate possession of a consigned Lamborghini. The court held that section 672.401(2), Florida Statutes, requires 'physical delivery' for title to pass and cannot be satisfied by constructive delivery, and that genuine disputes of material fact existed as to whether the vehicle was ever physically delivered to the buyer.
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