ARMANDO PALMA

v.

REGIONS BANK

MILLER, J. Appellant, Armando Palma, appeals from an order denying his motion to quash a writ of garnishment. We have jurisdiction. See Fla. R. App. P. 9.130(a)(3)(C)(ii). Palma asserts on appeal that the trial court erred in rejecting his contention that a release of lien executed by appellee, Regions Bank, precluded further collection efforts. Discerning no error, we affirm.

I

In 2009, Regions brought suit against Palma for breach of a promissory note. On February 8, 2011, the trial court entered a final summary judgment in favor of Regions in the amount of $118,436.20. Regions recorded the judgment in Book 27643, Page 4014 of the Official Records of Miami-Dade County, creating a statutory lien on Palma's real property in Miami Beach, Florida.

Some seven months later, Palma sold the Miami Beach property in a short sale. The net proceeds were divided among three lienholders. The first mortgagee received $340,611.85. Regions was denominated as the second mortgagee, despite having never instituted a foreclosure action, and received $3,000.00. Yet a third mortgagee received $13,000.00. Regions was not a party to the settlement statement.

Around nine years later, Regions' former attorney executed a document entitled “RELEASE OF LIEN.” The instrument provided, in pertinent part:

For and in consideration of the sum of $3,000.00 and other good and valuable consideration in hand this day paid, the receipt of which is hereby acknowledged, REGIONS BANK, hereby releases the property hereinafter described from the lien of that certain Final Judgment filed in Official Records Book 27643, Page 4014, public records of Dade County, Florida. This instrument releases the judgment described at the aforesaid Book and Page, and operates as a release as to the named defendant(s) in that judgment only as to that certain property more particularly described as follows: [Palma's property].

After executing the release of lien, Regions unsuccessfully attempted to collect the balance of the judgment by engaging in discovery in aid of execution and issuing writs of garnishment. In 2025, Regions issued a writ of garnishment to Wells Fargo Bank, N.A. Palma moved to quash the writ, contending that the release of lien barred further collection efforts. The trial court disagreed, finding that the instrument only released the lien, not the judgment. This appeal ensued.

II

A

We review a lower court order construing a release de novo, as it implicates a pure question of law. See Escadote I Corp. v. Ocean Three Ltd. P'ship, 211 So. 3d 1059, 1062 (Fla. 3d DCA 2016).

B

Because a release is contractual, it is construed just as any other contract term or provision. See Santana v. Miller, 314 So. 3d 346, 348 (Fla. 3d DCA 2020). We thus begin with the cardinal rule of interpretation: ""[w]here the words of a contract in writing are clear and unambiguous, its meaning is to be ascertained in accordance with its plainly expressed intent.” M & G Polymers USA, LLC v. Tackett, 574 U.S. 427, 435 (2015) (quoting 11 Richard A. Lord, Williston on Contracts § 30:6 (4th ed. 2012)). It follows that courts are not authorized to rewrite contracts to engraft alternative or additional meanings. See Andersen Windows, Inc. v. Hochberg, 997 So. 2d 1212, 1214 (Fla. 3d DCA 2008).

Palma asserts that a textual reading of the release of lien compels the conclusion that Regions discharged his liability on the judgment or, alternatively, the payment from the short-sale proceeds equates with an accord and satisfaction. He principally relies on the phrase "[t]his instrument releases the judgment described at the aforesaid Book and Page” for the proposition that Regions intended to broadly extinguish any liability for the 2009 judgment.

Palma's argument rests on a strained reading of an isolated phrase. This approach runs afoul of the whole-text canon, which requires us to view

"the entire text, in view of its structure and of the physical and logical relation of its many parts." Lab'y Corp. of Am. v. Davis, 339 So. 3d 318, 324 (Fla. 2022) (quoting Antonin Scalia & Bryan A. Garner, Reading Law: The Interpretation of Legal Texts 167 (2012)). Noting that the canons “can aid the interpretive process from beginning to end" and that the contract must be read as a whole, we take a more holistic approach. Conage v. United States, 346 So. 3d 594, 598 (Fla. 2022); see also Scalia & Garner, supra, at 180 ("The provisions of a text should be interpreted in a way that renders them compatible, not contradictory.").

Here, the release is titled "release of lien" rather than “release of judgment.” The text within the body is consistent with this distinction. Regions first narrowly “releases the property" from the judgment lien and then reiterates that it is releasing Palma from the judgment "only as to [the Miami Beach property]." The collective effect of these provisions is clear and unambiguous-Regions bargained to release its judgment lien in exchange for receiving a portion of the short-sale proceeds. It did not purport to otherwise extinguish its judgment.

Palma's alternative argument of accord and satisfaction yields no contrary conclusion. An essential element of the doctrine is proof a claim was unliquidated or subject to a preexisting dispute. See Brody Irrevocable

Grantor Tr. No. 2 v. Brody, 322 So. 3d 150, 154 (Fla. 2d DCA 2021) (“[I]n order to support that the parties intended to effect an accord and satisfaction, either (a) there needed to be a preexisting dispute about the amount owed... or (b) the payment needed to be partial, pursuant to a mutual understanding that the reduced amount would completely satisfy the original obligation.").

Here, the opposite is true. The claim was liquidated years before the release of lien was executed. There is no dispute over the amount in the record, and as discussed, the release self-limits to the judgment lien. Accordingly, we affirm the order under review in all respects.

Affirmed.