KAC 2021-1, LLC v. American Homes 4 Rent Properties One, LLC
An assignee of a former tenant sued a residential landlord under the FCCPA (§ 559.72(5)), alleging the landlord improperly disclosed the tenant's debt by posting the statutory three-day notice of nonpayment on the door with the text facing outward. The Second District affirmed dismissal, holding that posting the statutorily required three-day notice under section 83.56 is 'necessarily preliminary' to an eviction action and therefore absolutely protected by the litigation privilege as a matter of law.
Key facts
- KAC 2021-1, LLC, an assignee of a former tenant's debt, sued American Homes 4 Rent Properties One, LLC, a residential landlord, under the FCCPA § 559.72(5), alleging improper disclosure of the tenant's nonpayment debt by posting a statutory three-day notice with text facing outward on the rental property door.
- The trial court dismissed the complaint; the Second District affirmed, holding that posting a three-day notice of nonpayment under section 83.56 is necessarily preliminary to an eviction action and therefore absolutely protected by Florida's litigation privilege as a matter of law.
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Why it matters
This gives residential landlords and their counsel a direct appellate holding that the standard face-out posting of a three-day notice cannot support an FCCPA § 559.72(5) disclosure claim, blunting a wave of… — full analysis with a trial
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