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4th DCAJune 24, 2026Reversed and Remanded🔬 Novel Issue

James Gorfin v. Frederick William Hall, Woodside Credit, LLC, et al.

Case No. 2025-3046

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.

Key facts

  • Gorfin consigned his 2014 Lamborghini Aventador to a car dealership for sale.
  • Hall contracted to buy the vehicle for $357,000, wired an $81,000 down payment, and was given keys at the dealership but never received the title or departed with the car, instead leaving it for exhaust installation and repairs.
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Holdings

  • Under section 672.401(2), Florida Statutes, title to goods passes to the buyer only upon the seller's 'physical delivery'; the modifier 'physical' must be given meaning and therefore…
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Why it matters

This decision gives UCC and commercial-transaction practitioners a clear statement that section 672.401(2)'s 'physical delivery' requirement is not satisfied by constructive delivery, distinguishing the title-passage… — full analysis with a trial

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