Wynne Building Corporation v. Spanish Lakes Country Club Village Homeowner's Association, Inc., and Spanish Lakes-Golf Village Homeowners Association, Inc.
The Fourth District held that Florida Rule of Civil Procedure 1.222 permits a single mobile homeowners' association to bring a class action on behalf of its own members, but does not allow multiple associations to band together in one class action on behalf of members across multiple associational memberships. The court reversed certification of the combined six-count class action and remanded for the trial court to assess, association-by-association and claim-by-claim, whether each may maintain a Rule 1.222 class action, while noting the court retains broad discretion to consolidate related actions.
Key facts
- Two distinct mobile homeowners' associations, representing distinct sets of member-homeowners but sitting on geographically proximate land owned by the same owner (Wynne Building Corporation), jointly brought a six-count amended complaint challenging allegedly unreasonable lot rent increases.
- The complaint sought, for each association, declaratory relief on 2021-22 and 2022-23 rent increases and damages, alleging a right to be represented as a class under Florida Rule of Civil Procedure 1.222 and section 723.037, Florida Statutes.
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Holdings
- Rule 1.222 authorizes one mobile homeowners' association to bring a class action in its own name on behalf of its own members; it does not authorize multiple associations to bring a single…
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Why it matters
This is the first Florida appellate construction of Rule 1.222 addressing multi-association class actions, and it imports the court's Rule 1.221 condominium-association jurisprudence (including Century Village East) to… — full analysis with a trial
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