The Waterfront in Naples Condominium Association, Inc. v. Reynolds Ventures, Inc.
After nonbinding arbitration in a construction lien case, the condominium association timely filed a "Motion and Request for Trial De Novo" but did not use the words "notice of rejection" required by the 2024 amendment to Fla. R. Civ. P. 1.820(h). The trial court sua sponte struck the filing, unsealed the arbitration award, and entered judgment on it. The Sixth DCA reversed, holding that rule 1.820(h) imposes no magic-words test and that a timely document announcing a request for trial de novo from a specified arbitration award fairly constitutes the required notice of rejection; it certified conflict with the Third and Fourth Districts.
Key facts
- Waterfront in Naples Condominium Association filed a timely Motion and Request for Trial De Novo challenging a nonbinding arbitration award in a construction lien dispute, but did not use the specific words 'notice of rejection' required by the 2024 amendment to Fla. R. Civ. P. 1.820(h).
- The trial court sua sponte struck the association's filing, unsealed the arbitration award, and entered judgment on it, denying the association's right to trial de novo.
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Why it matters
This is a direct, certified district conflict on the 2024 amendment to rule 1.820(h) that is highly likely headed to the Florida Supreme Court, and it governs whether a litigant loses its right to a jury trial after… — full analysis with a trial
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