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6th DCAAugust 21, 2026Reversed and Remanded⚡ Circuit Split Resolved

The Waterfront in Naples Condominium Association, Inc. v. Reynolds Ventures, Inc.

Case No. 6D2025-0623

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.

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