Systemax, Inc. v. Fiorentino
Systemax, the victim named in a federal criminal restitution order against its former executive, recorded the restitution judgment in Florida and sought to collect it through state-court execution discovery. The Third DCA held as a matter of first impression that 18 U.S.C. § 3664(m)(1) of the MVRA permits a private victim only to obtain and record an abstract of judgment as a lien — the United States alone may enforce a federal restitution order — so the trial court properly stayed discovery, entered a protective order, and dissolved the lis pendens. The court reversed, however, on the trial court's failure to require security for the stay under section 55.509(2), Florida Statutes.
Key facts
- Systemax, Inc., a crime victim named in a federal criminal restitution order against a former executive, recorded the restitution judgment in Florida and sought to collect it through state-court execution discovery against the judgment debtor.
- The trial court stayed the execution discovery, entered a protective order, and dissolved the lis pendens recorded by Systemax, but did not require the judgment debtor to post security for the stay.
- +2 more key facts with a free trial
Why it matters
This is a first-impression construction of the MVRA's enforcement provision in Florida (and the court found no federal case on the narrow point), giving counsel a clear rule: a crime victim who records a federal… — full analysis with a trial
Read the full opinion, holdings & search — free for 30 days
The full opinion PDF, the rules the court applied, our significance analysis, the background facts, and full-text search across every tracked Florida decision — in your hands.
- Search every tracked Florida decision in seconds
- Save, tag & file the cases that matter into your own library
- Read the full plain-English analysis and holdings
Not ready to sign up? Get the free Friday digest — the week's key Florida decisions by email, no login required.
Florida Court Tracker provides summaries of publicly available court opinions for informational and research purposes only. This is not legal advice and does not create an attorney–client relationship. Always verify holdings against the official opinion.