Ross-Williams v. Leali
A judgment creditor of a condominium association invoked proceedings supplementary under sections 56.10 and 56.29 and obtained appointment of a post-judgment receiver whose 'primary fiduciary duty' was to pay the judgment. After the judgment was satisfied, the trial court granted the receiver's ex parte motion to expand the receivership to give her plenary operational authority over the association. The Third District reversed, holding that the statutory authority for a section 56.10 receivership ends upon satisfaction of the underlying judgment.
Key facts
- Judgment creditor of a condominium association obtained a post-judgment receiver under Florida's proceedings supplementary statute (section 56.10) with primary duty to satisfy the judgment.
- After the judgment was paid in full, the trial court granted the receiver's ex parte motion to expand her authority to take over plenary operational control of the association.
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Why it matters
Practitioners defending corporate or association judgment debtors now have clear Third District authority that a section 56.10 post-judgment receivership terminates with satisfaction of the judgment and cannot be… — full analysis with a trial
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