VANESSA COHN
v.
FRANCESCO B. MUTTI, INDIVIDUALLY AND AS TRUSTEE OF THE MONA OLOFFSON TRUST

Fla. 4th DCA | 2024-01-17
No. 2022-3211
2024 FL 597 Florida District Court of Appeal, Fourth District (2024)

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Holding

A judgment granting affirmative relief not requested in the pleadings and not tried by consent is void and must be vacated, unless the court provides notice under Florida Rule of Civil Procedure 1.510(f).


Headnotes

[1] A trial court may not grant affirmative relief not requested in the pleadings or tried by consent unless it provides notice to the parties under Florida Rule of Civil Pro…

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Key Quotes

“a judgment granting relief not requested in the pleadings is void and should be vacated”

Court citing Bank of N.Y. Mellon v. Reyes, 126 So. 3d 304, 309 (Fla. 3d DCA 2013)

Facts & Procedural History

Vanessa Cohn appealed a circuit court's order that partially granted summary judgment for specific performance and awarded partial ownership of proper…

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Opinion of the Court

vacated). The circuit court awarded partial ownership of the property to each party, something neither party sought.1 Based on our conclusion on the first issue, we need not address Cohn’s argument regarding the election of remedies. However, on the record before us, we affirm the circuit court’s denial of Cohn’s motion for summary judgment. We reverse the circuit court’s summary judgment order and remand for further proceedings. Reversed and remanded. KLINGENSMITH, C.J., KUNTZ and ARTAU, JJ., concur.

* * * Not final until disposition of timely filed motion for rehearing.

Footnotes
1 With notice a court may grant summary judgment on grounds not sought by either party. See Fla. R. Civ. P. 1.510(f). But, here, the court did not provide notice.

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