MICHAEL J. SWERDLOW
v.
ROYAL OAKS LANE (BISCAYNE LANDING) - NORTH MIAMI LLC

Fla. 3d DCA | 2024-11-06
No. 2023-2072
2024 FL 12667 Florida District Court of Appeal, Third District (2024)

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Synopsis

The Third District Court of Appeal affirmed the trial court's decision regarding a mortgage foreclosure action involving a deficiency decree. The court held that a trial court's discretionary decisions in foreclosure matters are reviewed for abuse of discretion and should not be disturbed on appeal absent a clear showing of abuse.


Holding

The trial court's decision to grant a deficiency decree was affirmed. A trial court's exercise of sound judicial discretion regarding deficiency judgments in foreclosure actions consonant with equity will not be disturbed on appeal unless there is a clear showing of abuse of discretion.


Key Quotes

“The granting of a deficiency decree in a mortgage foreclosure action is a matter for the sound judicial discretion of the trial court. Generally, the granting of a deficiency judgment is the rule rather than the exception, unless there are facts and circumstances creating equitable considerations upon which a court should deny the deficiency decree in the exercise of its discretion.”

Establishes the governing standard that deficiency decrees are generally granted unless equitable considerations warrant denial, and that trial courts have discretion in this matter.

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Facts & Procedural History

The case involves a mortgage foreclosure action between Michael J. Swerdlow and Royal Oaks Lane (Biscayne Landing) - North Miami LLC. The trial court …

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Opinion of the Court

PER CURIAM.

Affirmed. See S/D Enterprises, Inc. v. Chase Manhattan Bank, 374 So. 2d 1121, 1122 (Fla. 3d DCA 1979) (“The granting of a deficiency decree in a mortgage foreclosure action is a matter for the sound judicial discretion of the trial court. Generally, the granting of a deficiency judgment is the rule rather than the exception, unless there are facts and circumstances creating equitable considerations upon which a court should deny the deficiency decree in the exercise of its discretion.

Thus, an exercise of sound judicial discretion consonant with equity in the light of the facts should not be disturbed on appeal unless there is a showing of a clear abuse of sound judicial discretion.”) (internal citations omitted); Lasar Mfg. Co., Inc. v. Bachanov, 436 So. 2d 236, 237 (Fla. 3d DCA 1983) (“It is well settled that a trial court’s decision to permit or refuse amendment to pleadings will not be disturbed on appeal in the absence of an abuse of discretion.”).


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