TRUMP ENDEAVOR 12, LLC, APPELLANT,
v.
FLORIDA PRITIKIN CENTER, LLC, APPELLEE
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Trump Endeavor 12, LLC appealed a declaratory judgment in favor of Florida Pritikin Center, LLC regarding lease extension and room rate disputes at the Trump National Doral Miami. The appellate court reversed and remanded because the trial court failed to include required findings of fact and conclusions of law in its judgment.
Reversal is warranted because findings of fact and conclusions of law are required when reviewing declaratory judgments, and their absence precludes meaningful appellate review.
[1] A final judgment granting declaratory relief is reversible when the trial court fails to provide sufficient findings of fact and conclusions of law, thus precluding meani…
[2] Appellate courts typically remand cases for necessary findings of fact and conclusions of law when the lower court's orders do not contain sufficient factual findings.
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Join FLexlaw to unlock all legal intelligence“Reversal is warranted because the trial court failed to provide sufficient findings of fact and conclusions of law, thus precluding meaningful review by this Court.”
States the core legal requirement and basis for reversal in this case.
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Join FLexlaw to unlock all legal intelligenceIn March 2009, Pritikin entered into a Lease Agreement and Group Room Agreement with the former owners of the Doral Resort and Spa, granting Pritikin …
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Trump Endeavor 12, LLC appeals a Final Judgment for declaratory relief in favor of Florida Pritikin Center, LLC. Trump contends that the Final Judgment and the incorporated Amended Joint Verdict Form were void of any findings of facts and/or conclusions of law. We agree and thus reverse.
In March 2009, Florida Pritikin Center, LLC and the former owners of the Doral Resort and Spa entered into a Lease Agreement granting Pritikin the exclusive right to use and occupy a portion of the Doral Resort in order to operate Pritikin Longevity Center & Spa, and for shared, non-exclusive use of other areas of the Doral Resort. Pritikin and Doral Resort and Spa also entered into a Group Room Agreement granting Pritikin exclusive rights to use up to 100 standard guest rooms and up to 10 suites at a contractually fixed rate.
Trump then purchased the Doral Resort out of bankruptcy, renamed it the Trump National Doral Miami and expressly assumed the Pritikin Lease and Group Room Agreement. In May 2014, Pritikin filed a lawsuit against Trump seeking declaratory relief to establish whether its lease extension was properly exercised per the terms of the Lease and Group Room Agreement (Count I); and to resolve a dispute regarding room rates (Count II). The Complaint was later amended to seek declaratory relief regarding Trump Endeavor’s June 18, 2014 Notice of Termination of the lease (Count III).
The trial court eventually entered an order granting Pritikin’s Motion for Partial Summary Judgment on Counts I and II. The court found that Pritikin had “validly exercised it’s first of three extension options in accordance with Section 3.3a(i)(iii) of the Lease,” and determined the daily room rates were adjusted correctly pursuant to paragraph 3d of the Group Room Agreement.
After a four-day bench trial in February 2015, the trial court entered a declaratory Final Judgment for Pritikin, incorporating the March 25, 2015 Amended Joint Verdict Form and Summary Judgment Order. The Final Judgment stated no findings of fact or conclusions of law.
Reversal is warranted because the trial court failed to provide sufficient findings of fact and conclusions of law, thus precluding meaningful review by this Court. Findings of fact and conclusions of law are required to review declaratory judgments. Featured Properties, LLC v. BLKY, LLC, 65 So.3d 135 (Fla. 1st DCA 2011) (“ ‘[w]here .,. orders do not contain sufficient findings of fact, ... appellate courts typically deem them incapable of meaningful review and they remand with directions to the issuing courts to make the necessary findings.’ ”) (quoting In re Doe, 932 So.2d 278, 283 (Fla. 2d DCA 2005)); Weatherford v. City of Hialeah, 537 So.2d 680, 682 (Fla. 3d DCA 1989); Breuil v. Hobbs, 166 So.2d 825 (Fla. 3d DCA 1964).
Accordingly, we reverse and remand the Final Judgment to the trial court with instructions to enter the necessary orders making sufficient findings of fact and conclusions of law.
Reversed and remanded.
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Sears v. Forbes/Cohen Fla. Props., L.P., 223 So. 3d 292 (Fla. 4th DCA 2017)…rds usually found in cases seeking only a money judgment. rather than a declaratory judgment”). Review of a declaratory judgment generally requires adequate fíndiñgs of fact and conclusions of law. Trump Endeavor 12, LLC v. Fla. Pritikin Ctr., LLC, 208 So. 3d 311, 312 (Fla. 3d DCA 2016). Thus, normally, we would remand for the trial court to make additional findings. See Exotic Motorcars & Jewelry, Inc. v. Essex Ins. Co., 111 So. 3d 208, 209 (Fla. 4th DCA 2013). However, in the present case, the issues to be…
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Naples Ests. Ltd. P'ship v. Glasby, 331 So. 3d 863 (Fla. 2d DCA 2021)…nces, most often when findings are required by legislative mandate, the lack of such findings could result in a remand for such findings. See S.L.V. v. Toth, 268 So. 3d 801, 803 (Fla. 4th DCA 2019); Trump Endeavor 12, LLC v. Fla. Pritikin Ctr. LLC, 208 So. 3d 311, 312 (Fla. 3d DCA 2016). Having recognized that neither the record on appeal nor the final judgment entered by the trial court identify its findings of fact, we are required to apply the traditional rules that govern this court's review of the trial…
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S.L.V. v. Arpad Toth, 268 So. 3d 801 (Fla. 4th DCA 2019)…view of a declaratory judgment generally requires adequate findings of fact and conclusions of law. See Exotic Motorcars & Jewelry, Inc. v. Essex Ins. Co. , 111 So. 3d 208, 209 (Fla. 4th DCA 2013) ; Trump Endeavor 12, LLC v. Fla. Pritikin Ctr. LLC , 208 So. 3d 311, 312 (Fla. 3d DCA 2016). This problem is amplified by the absence of any record of the trial court proceedings. Because it is entirely unclear on what basis the trial court dismissed the declaratory relief complaint, the final judgment is inadequate…
Previewing 3 of 4 citing cases — full citator treatment, depth of discussion, and citing context are member features.
Join FLexlaw to unlock all legal intelligenceAuthorities Cited
- In re Petition of Jane DOE for a Judicial Waiver of Parental Notice of Termination of Pregnancy. Jane Doe, 932 So. 2d 278 (Fla. 2d DCA 2005)
- Featured Props., LLC v. Blky, LLC, 65 So. 3d 135 (Fla. 1st DCA 2011)
- Weatherford v. The City OF Hialeah, 537 So. 2d 680 (Fla. 3d DCA 1989)
- Breuil v. Hobbs, 166 So. 2d 825 (Fla. 3d DCA 1964)