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.
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