MICHAEL V. GREENAN
v.
HOMETOWN TITLE & CLOSING SERVICES, LLC
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An appellant must make timely, contemporaneous objections stating specific legal grounds in the trial court to preserve issues for appellate review.
[1] To preserve an issue for appellate review, a party must make a timely, contemporaneous objection stating a specific legal ground, and the argument on appeal must correspo…
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Join FLexlaw to unlock all legal intelligence“proper preservation entails three components. First, a litigant must make a timely, contemporaneous objection. Second, the party must state a legal ground for that objection. Third, '[i]n order for an argument to be cognizable on appeal, it must be the specific contention asserted as legal ground for the objection, exception, or motion below.'”
Court's statement of the three-part test for issue preservation on appeal
Michael V. Greenan appealed a decision from Charlotte County Court against Hometown Title & Closing Services, LLC. The appeal involved issues that wer…
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SIXTH DISTRICT COURT OF APPEAL
STATE OF FLORIDA
Case No. 6D2025-2101 Lower Tribunal No. 2025-CC-000052
MICHAEL V. GREENAN, Appellant,
v.
HOMETOWN TITLE & CLOSING SERVICES, LLC, Appellee.
Appeal from the County Court for Charlotte County. Sean Lux, Judge.
July 24, 2026
PER CURIAM.
AFFIRMED. See Harrell v. State, 894 So. 2d 935, 940 (Fla. 2005) ("Moreover, we consistently have stated that proper preservation entails three components. First, a litigant must make a timely, contemporaneous objection. Second, the party must state a legal ground for that objection. Third, ‘[i]n order for an argument to be cognizable on appeal, it must be the specific contention asserted as legal ground for the objection, exception, or motion below." (quoting Steinhorst v. State, 412 So. 2d 332, 338 (Fla. 1982))); Fi-Evergreen Woods, LLC v.
Robinson, 135 So. 3d 331, 333 n.2 (Fla. 5th DCA 2013) (“To preserve an issue for appellate review, the appellant must have obtained, inter alia, a ruling in the lower tribunal." (citing Carratelli v. State, 832 So. 2d 850, 856 (Fla. 4th DCA 2002))); Stanton v. Fla. Dep't of Health, 129 So. 3d 1083, 1085 (Fla. 1st DCA 2013) (“It is a well-established maxim of appellate practice that '[c]laims for which an appellant has not presented any argument, or for which he provides only conclusory argument, are insufficiently presented for review and are waived." (quoting Hammond v. State, 34 So. 3d 58, 59 (Fla. 4th DCA 2010))).
WOZNIAK, MIZE and PRATT, JJ., concur.
Michael V. Greenan, Mathews, Virginia, pro se.
Jennifer L. Mantoni, of Mantoni Legal, P.A., Port Charlotte, for Appellee.
NOT FINAL UNTIL TIME EXPIRES TO FILE MOTION FOR REHEARING
AND DISPOSITION THEREOF IF TIMELY FILED
2
Cases With Similar Vibessemantic neighbors from the corpus
Citator
Authorities Cited
- Steinhorst v. State, 412 So. 2d 332 (Fla. 1982)
- Harrell v. State, 894 So. 2d 935 (Fla. 2005)
- Carratelli v. State, 832 So. 2d 850 (Fla. 4th DCA 2002)
- Hammond v. State, 34 So. 3d 58 (Fla. 4th DCA 2010)
- Stanton v. Fla. Dep't OF Health, 129 So. 3d 1083 (Fla. 1st DCA 2013)