Patterson v. Van Diepen
A residential tenant failed to deposit past-due rent into the court registry, and the county court entered a default final judgment for possession plus a $7,800 damages judgment. The First DCA affirmed the possession judgment — holding the registry-deposit failure under section 83.60(2) absolutely waived all defenses other than payment, including failure to join an indispensable party — but reversed the damages award because the registry statute applies only to possession claims.
Key facts
- Residential tenant failed to pay past-due rent and did not deposit accrued rent into the court registry as required by section 83.60(2), Florida Statutes.
- County court entered a default final judgment for possession of the dwelling unit and awarded $7,800 in damages to the landlord.
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Why it matters
The opinion extends to the residential context (section 83.60(2)) the rule previously developed under the nonresidential registry statute (section 83.232(5)) that a registry-deposit default resolves only possession, not… — full analysis with a trial
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