Maidel de Armas, Geidy Rodriguez, Janet de Armas, and Emilio de Armas v. Emilio de Armas
The Third District reversed summary judgment in a quiet title action where the operative 2021 quitclaim deed named a grantee whose name was shared by both the father and the son. Because the shared name created a latent ambiguity, the trial court properly looked to parol evidence — but that parol evidence conflicted. A court may construe an instrument as a matter of law only when it is unambiguous or when any ambiguity is resolved by undisputed parol evidence, so the conflict created a genuine issue of material fact precluding summary judgment.
Key facts
- A family dispute arose over ownership of Miami-Dade real property in which a father and his son share the identical name, Emilio de Armas.
- The son sued to quiet title, among other claims, relying on a 2021 quitclaim deed naming 'Emilio de Armas' as grantee.
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Holdings
- A deed identifying a grantee by a name shared by two potential claimants presents a latent ambiguity, which a court may resolve by considering parol evidence.
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Why it matters
A clean, citable reminder that Florida's post-2021 federal summary judgment standard still does not permit a trial court to weigh conflicting extrinsic evidence. Real property and title practitioners should note the… — full analysis with a trial
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