31 FORD LLC
v.
TENANT'S RIGHTS LLC AS ASSIGNEE TO MARIE ZULME
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A plaintiff must allege specific facts in the complaint establishing a basis for venue, and a generalized citation to the applicable venue rule is insufficient to satisfy this pleading requirement.
[1] A plaintiff asserting venue in a particular county must allege specific facts in the complaint establishing a factual basis for that venue; a mere citation to the applica…
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Court citing Nicholas v. Ross, 721 So. 2d 1241, 1242 (Fla. 4th DCA 1998)
31 Ford LLC, a landlord, sought to dismiss or transfer a security deposit dispute brought by Tenant's Rights LLC as assignee to Marie Zulme in Palm Be…
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DISTRICT COURT OF APPEAL OF THE STATE OF FLORIDA
FOURTH DISTRICT
31 FORD LLC, Appellant,
V.
TENANT'S RIGHTS LLC, as assignee to MARIE ZULME, Appellee.
No. 4D2026-0312
[July 1, 2026]
Appeal from the County Court for the Fifteenth Judicial Circuit, Palm Beach County; Sara Alijewicz, Judge; L.T. Case No. 502025SC017323XXXAWB.
Michael Ira Bernstein, Matthew Savino and Jordan Charles Kaplan of The Bernstein Law Firm, Miami, for appellant.
Daniel William Bialczak of Korte & Associates, PLLC, Palm Beach Gardens, for appellee.
LOTT, J.
31 Ford LLC (“Landlord") appeals an order denying its motion to dismiss or transfer venue of a suit brought in Palm Beach County for return of a security deposit. We reverse based on Casa Verde MHC, LLC v. Tenant's Rights LLC, No. 4D2025-2002, 2026 WL 1154014 (Fla. 4th DCA Apr. 29, 2026).
As in Casa Verde, the face of appellee's complaint failed to allege a basis for venue in Palm Beach County. See id. (citing Nicholas v. Ross, 721 So. 2d 1241, 1242 (Fla. 4th DCA 1998) (“[T]he plaintiff must allege in the complaint a sufficient basis for the selected venue.”)). The complaint's generalized citation to Florida Small Claims Rule 7.060 is insufficient for appellee to satisfy its burden to plead venue. See Fla. Sm. Cl. R. 7.060(a) (listing seven permissible filing locations).
Consequently, we reverse and remand with directions to grant Landlord's motion and transfer this action to Miami-Dade County court.
Reversed and remanded.
GROSS and SHAW, JJ., concur.
* * *
Not final until disposition of timely-filed motion for rehearing.