ROMAN RAVELO
v.
MARIA D. PAYRET

Fla. 3d DCA | 2025-03-12
No. 3D2023-1840
343 So. 3d 689 Florida District Court of Appeal, Third District (2025) Positive Treatment
Cited by 4 cases

AI-generated. These summaries, headnotes, and key points are machine-generated and may contain errors or omissions. Always verify against the full opinion text below. Not legal advice.

Synopsis

Roman Ravelo appeals the trial court's order denying his rule 1.540(b) motion to vacate a default final judgment following an evidentiary hearing on remand. This is Ravelo's second appeal in the case; the court previously reversed and remanded for an evidentiary hearing to determine whether relief should be granted.


Holding

The court affirmed the trial court's order denying the motion to vacate the default final judgment, finding that the trial court did not grossly abuse its discretion in making this determination.


Headnotes

[1] The standard of review for an order denying a motion to vacate a default final judgment is gross abuse of discretion, which is more deferential than the mere abuse of dis…

Previewing 1 of 1 headnotes on this case. FLexlaw’s editorially structured points of law — every proposition, pinpointed — are reserved for members.

Join FLexlaw to unlock all legal intelligence

Facts & Procedural History

Ravelo obtained a default final judgment against him in the underlying case. He filed a rule 1.540(b) motion to vacate the default judgment. After the…

The full statement of facts, procedural history, and disposition for this case are member content.

Join FLexlaw to unlock all legal intelligence

© FLexlaw, Inc. — AI-generated enrichments are proprietary. All rights reserved.


Opinion of the Court

Opinion filed March 12, 2025. Not final until disposition of timely filed motion for rehearing.

________________ No. 3D23-1840 Lower Tribunal No. 17-7556 ________________

Roman Ravelo,

Appellant,

vs.

Maria D. Payret, Appellee.

An Appeal from the Circuit Court for Miami-Dade County, Vivianne del Rio, Judge. Law Offices of Mark A. Dienstag, and Mark A. Dienstag; Law Offices of Karen J. Haas, and Karen J. Haas, for appellant. Law Offices of Solangel Verde, and Solangel Verde; Law Offices of Kevin W. Nates, and Kevin W. Nates, for appellee. Before EMAS, SCALES and MILLER, JJ. EMAS, J.

This case returns to us for a second time. In a prior appeal, Roman Ravelo challenged the trial court’s summary denial of his rule 1.540(b) motion to vacate a default final judgment, and this court reversed and remanded for an evidentiary hearing to determine whether relief should be granted. Ravelo v. Payret, 335 So. 3d 811 (Fla. 3d DCA 2022). In this second appeal, Ravelo challenges the trial court’s subsequent order, denying his motion to vacate following an evidentiary hearing on remand.

This Court reviews an order denying a motion to vacate a default final judgment for a gross abuse of discretion. Karan v. Pernia, 343 So. 3d 689, 690 (Fla. 3d DCA 2022) (citing Brivis Enters., Inc. v. Von Plinski, 8 So. 3d 1208, 1209 (Fla. 3d DCA 2009) to note “the distinction” between the standard of review for an order denying a motion to vacate an interlocutory order of default, “mere abuse of discretion,” and the standard of review for an order denying a motion to vacate a default final judgment, “gross abuse of discretion”) (other citations omitted); see also Finkel Outdoor Prods., Inc. v. Lasky, 529 So. 2d 317, 318 (Fla. 2d DCA 1988) (“A mere abuse of discretion is sufficient to warrant reversal of a trial judge’s refusal to vacate an interlocutory order of default as opposed to a gross abuse of discretion needed to reverse a refusal to vacate a default judgment.”) (alteration in original) (citing N. Shore Hosp., Inc. v. Barber, 143 So. 2d 849 (Fla. 1962) and Kapetanopoulos v. Herbert, 449 So. 2d 947 (Fla. 2d DCA 1984)).

Upon our review, and applying this highly deferential standard, we cannot say the trial court grossly abused its discretion in denying the motion to vacate the default final judgment. We affirm the order on appeal.

Affirmed.


Cases With Similar Vibessemantic neighbors from the corpus


Citator

Cited By

  • Ravelo v. Payret, 343 So. 3d 689 (Fla. 3d DCA 2025)
    …Ravelo challenged the trial court’s summary denial of his rule 1.540(b) motion to vacate a default final judgment, and this court reversed and remanded for an evidentiary hearing to determine whether relief should be granted. Ravelo v. Payret, 335 So. 3d 811 (Fla. 3d DCA 2022). In this second appeal, Ravelo challenges the trial court’s subsequent order, denying his motion to vacate following an evidentiary hearing on remand. This Court reviews an order denying a motion to vacate a default final ju…
    1 / 2
  • …o gross abuse of discretion, see Lewis v. Fifth Third Mortg. Co., 38 So. 3d 157, 160 (Fla. 3d DCA 2010) (noting that a trial court's denial of a motion to vacate a default final judgment is reviewed for a gross abuse of discretion); Karan v. Pernia, 343 So. 3d 689, 690 (Fla. 3d DCA 2022), and, to the extent the order on appeal was premised upon questions of law, see Emami v. Progressive Brands, Inc., 225 So. 2d 983 (Fla. 3d DCA 2017) (noting that whether judgment is void is a question of law reviewed de novo)…
  • Liansy C. Carbonell v. Glade, 394 So. 3d 679 (Fla. 3d DCA 2024)

Previewing 3 of 4 citing cases — full citator treatment, depth of discussion, and citing context are member features.

Join FLexlaw to unlock all legal intelligence

Authorities Cited

Full citator, related cases, and AI research tools

Open in FLexlaw