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3rd DCAAugust 6, 2026Affirmed⭐ Notable

Natalia Carolinni Souza de Sa v. Star Blue Corporation, et al.

Case No. 2025-1661

The Third District affirmed by citation opinion in an appeal arising from a Florida Rule of Civil Procedure 1.540(b)(3) motion for relief from judgment based on alleged fraud. The court reaffirmed that such a motion must specify the essential facts of the purported fraud rather than assert legal conclusions or rehash matters already explored at trial, and that only a prima facie showing of fraud entitles a movant to an evidentiary hearing. It also restated that an appellate court is reactive and cannot decide issues the trial court never ruled on.

Key facts

  • Natalia Carolinni Souza de Sa, proceeding pro se, appealed from the Circuit Court for Miami-Dade County (Judge Jose M. Rodriguez) in litigation against Star Blue Corporation.
  • The appeal challenged the denial of relief sought under Florida Rule of Civil Procedure 1.540(b)(3), which permits relief from a judgment for fraud, misrepresentation, or other misconduct of an adverse party.
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Holdings

  • To warrant an evidentiary hearing, a rule 1.540(b)(3) motion must specify the essential facts of the purported fraud and may not merely assert legal conclusions; the specificity requirement…
  • +2 more holdings with a free trial

Why it matters

This citation opinion is a useful authority for defending post-judgment fraud attacks under rule 1.540(b)(3), a recurring feature of commercial and consumer litigation. It confirms that the pleading burden is… — full analysis with a trial

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