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The Waterfront in Naples Condominium Association, Inc. v. Reynolds Ventures, Inc.

2026-08-21

Summary

Holding. The appellate court reversed the trial court's final judgment confirming the arbitration award and remanded for trial on the merits because the Association's timely-filed motion requesting a trial de novo satisfied Florida Rule of Civil Procedure 1.820(h) and Section 44.103(5), and the trial court erred in sua sponte striking the motion.

The Waterfront in Naples Condominium Association hired Reynolds Ventures to perform water damage and mold remediation services following Hurricane Ian. When the Association declined to pay Reynolds' final invoice, Reynolds sued for breach of contract, construction lien foreclosure, and unjust enrichment. The parties went to non-binding arbitration. Within the required 20-day window, the Association filed a motion requesting a trial de novo but did not expressly use the phrase "notice of rejection of the arbitration decision." The trial court sua sponte struck the motion, finding it violated the amended Florida Rule of Civil Procedure 1.820(h), which was amended two months before the arbitration hearing to require that parties file a "notice of rejection of the arbitration decision and request for trial" in a single document. The trial court entered final judgment based on the arbitration award without allowing the Association an opportunity to address the procedural deficiency.

On appeal, the Association argued it was entitled to a trial on the merits. The appellate court rejected a requirement for specific "magic words" and instead applied a plain-meaning textualist analysis. The court found that the Association's document constituted a sufficient notice of rejection because it was a written announcement timely filed under the rule and statute explicitly requesting a trial de novo and challenging the specific arbitration award. The court concluded that interpreting the rule to require the exact phrase "notice of rejection" would amount to an impermissible hyperliteral reading. The court also noted the Association complied with the statutory requirement in Section 44.103(5), which requires only a timely request for trial de novo.

Summary generated by law.co from the public-domain opinion. The opinion text itself is public domain.

Key issues

  • Whether a request for trial de novo must contain the exact phrase 'notice of rejection' or whether a timely filing explicitly requesting trial while challenging the arbitration award satisfies the rule
  • The proper interpretation of the amended Florida Rule of Civil Procedure 1.820(h) and its relationship to Section 44.103(5), Florida Statutes
  • Whether procedural rules should be interpreted to defeat a party's substantive right to trial when the party has complied with the statute's core requirement

Procedural posture

The Association appealed from the trial court's final judgment entered after the court sua sponte struck its motion and request for trial de novo and unsealed an arbitration award, as well as the denial of its subsequent motion to vacate.

Authorities cited

Opinion

majority opinion

SIXTH DISTRICT COURT OF APPEAL

STATE OF FLORIDA

Case Nos. 6D2025-0624, 6D2025-0623

CONSOLIDATED

Lower Tribunal No. 2023-CA-002712

THE WATERFRONT IN NAPLES CONDOMINIUM ASSOCIATION, INC.,

Appellant,

v.

REYNOLDS VENTURES, INC.,

Appellee.

Appeal from the Circuit Court for Collier County.

Lauren L. Brodie, Judge.

August 21, 2026

BROWNLEE, J.

The Waterfront in Naples Condominium Association, Inc. (the “Association”)

appeals the final judgment entered in favor of Reynolds Ventures, Inc. (“Reynolds”),

and the denial of the motion to vacate that judgment. 1 The trial court entered the

final judgment after sua sponte striking the Association’s motion and request for trial

de novo and unsealing an arbitration award. Because we find the Association

1

The Association separately appealed the denial of its motion to vacate, and this court consolidated the two appeals for all purposes.

complied with the applicable statute and rule, we reverse and remand for a trial on

the merits.

THE RELEVANT FACTS

The Association owns a condominium complex that sustained damage after

Hurricane Ian. It hired Reynolds to perform water and mold remediation and

restoration services. After Reynolds believed it had completed its services, it sent a

final invoice to the Association, recorded a Claim of Lien, and served the

Association with the Contractor’s Final Payment Affidavit. The Association,

however, refused to pay, and Reynolds filed suit for breach of contract, foreclosure

on the construction lien, and unjust enrichment. Shortly thereafter, Reynolds

amended the complaint to reflect a reduced balance owed.

The parties eventually proceeded to non-binding arbitration. Twenty days

after the arbitrator’s decision, the Association filed a Motion and Request for Trial

De Novo, which stated the following:

Defendant, THE WATERFRONT IN NAPLES CONDOMINIUM

ASSOCIATION, INC., (“Defendant”), by and through its undersigned

counsel, and in accordance with Section 44.103(5), Florida Statutes,

and Florida rule of Civil Procedure 1.820(h), hereby moves for and

requests a trial de novo from the Non-Binding Arbitration Award dated

September 24, 2024, as to all claims.

After the Association requested a trial de novo, Reynolds filed an amended

complaint, and the Association filed six counterclaims, as well as an exhibit list and

a pretrial statement. Reynolds moved to strike the counterclaims.

2

But something curious happened at the hearing on the motion to strike. The

trial judge explained that, before she addressed the motion set for hearing, she

wanted to alert everyone that Florida Rule of Civil Procedure 1.820(h) had changed

two months before the arbitration took place in this case, and that the Association’s

motion and request for trial de novo did not comply with the new rule. She then read

the amended rule into the record and explained she had no choice but to deny the

Association’s motion and enter judgment pursuant to the arbitration award because

the rule “says that it has to be called a rejection of the arbitration decision, and a

request for trial de novo.” The trial court then found there was no reason to address

the merits of the motion that was set for hearing and asked Reynolds to prepare an

order stating that “the Court sua sponte is denying the motion pursuant to

noncompliance with the new rule.” She then explained that she would “have the

clerk unseal the arbitration ruling and enter judgment in conformance with the ruling

of the arbitrator.”

At that point, the Association interjected. It made an ore tenus motion to

continue the hearing and the ruling so that it could research the issue and respond. It

asked for an opportunity to provide “some sort of briefing to the Court and [to] have

a separate hearing” on the issue. The trial court responded that there would be no

hearing but that the Association could have forty-eight hours to submit something

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on point. She then directed Reynolds to prepare the order previously discussed and

concluded the hearing.

Two days later, the Association filed two documents: a memorandum in

opposition to the court’s ruling and a motion to vacate the court’s ruling or,

alternatively, a notice of rejection and request for trial de novo. Without a hearing,

the trial court entered an order that concluded as follows:

WHEREFORE, based on the foregoing information and evidence

before the Court, the Court’s own Motion to unseal the Arbitration

Award and Entry of Final Judgment, is hereby GRANTED and

Defendant’s Motion to Vacate and Notice of Rejection of Arbitration

Decision and Request for Trial De Novo filed February 14, 2025 is

untimely and cannot and will not be considered by the Court.

She then directed the clerk of court to unseal the arbitration award, and directed

whichever party prevailed under the award to prepare a final judgment. The court

later entered its final judgment in accordance with the non-binding arbitration award.

The Association moved for rehearing, raising substantially the same arguments as it

did in the memorandum of law and motion to vacate. The trial court summarily

denied that motion.

The Association now appeals. It raises six issues, arguing it is entitled to a

trial on the merits because: (1) it complied with section 44.103(5), Florida Statutes;

(2) it substantially complied with Florida Rule of Civil Procedure 1.820(h); (3) rule

1.820(h) violates the separation of powers because, as amended, it conflicts or adds

to the substantive provisions of section 44.103(5); (4) the trial court violated the

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Association’s due process rights when it deprived it of a full and fair opportunity to

be heard; (5) Reynolds waived strict compliance with rule 1.820(h) when it engaged

in litigation and prepared for trial; and (6) the final judgment should have been set

aside under rule 1.540(b) because any omission in the Association’s notice and

request for trial was due to excusable neglect.

While we do not agree with the Association on every argument raised, we

nonetheless find it was entitled to a trial de novo based on the motion and request

filed and that the trial court erred in sua sponte striking that document. We therefore

address only the dispositive issue and remand for a trial on the merits.

STANDARD OF REVIEW

“When a party timely requests a trial de novo following nonbinding

arbitration, this Court reviews the denial of the request de novo.” Dungarani v.

Benoit, 312 So. 3d 126, 128 (Fla. 5th DCA 2020) (citing Bacon Fam. Partners, L.P.

v. Apollo Condo. Ass’n, 852 So. 2d 882, 887 (Fla. 2d DCA 2003)).

ANALYSIS

The Statute, the Rule, and the Recent Cases

“Together, section 44.103 and Florida Rule of Civil Procedure 1.820 govern

court-ordered nonbinding arbitration.” Dungarani, 312 So. 3d at 128. Section

44.103, Florida Statutes, “prescribes the substance,” id. at 129, and simply requires

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a timely request for trial de novo in order to avoid the finality of the arbitration

decision:

An arbitration decision shall be final if a request for a trial de novo is

not filed within the time provided by rules promulgated by the Supreme

Court. The decision shall not be made known to the judge who may

preside over the case unless no request for trial de novo is made as

herein provided or unless otherwise provided by law. If no request for

trial de novo is made within the time provided, the decision shall be

referred to the presiding judge in the case who shall enter such orders

and judgments as are required to carry out the terms of the decision,

which orders shall be enforceable by the contempt powers of the court,

and for which judgments execution shall issue on request of a party.

§ 44.103(5), Fla. Stat. (2024).

Florida Rule of Civil Procedure 1.820(h) “prescribes the procedure for

requesting a trial de novo,” Dungarani, 312 So. 3d at 129, and was amended two

months before the arbitration award in this case. When amending the rule, the Florida

Supreme Court retitled subsection (h) “Notice of Rejection of the Arbitration

Decision and Request for Trial” and changed it “to clarify the process for rejecting

an arbitrator’s decision and requesting a trial de novo.” In re Amends. to Fla. R. Civ.

P., 386 So. 3d 876, 878 (Fla. 2024). The amended rule provides:

To reject the arbitration decision, within 20 days of service of the

arbitrator(’s)(s’) written decision, any party must file a notice of

rejection of the arbitration decision and request for trial in the same

document. No action or inaction by any party, other than the filing

of the notice, will be deemed a rejection of the arbitration decision.

. . . If a notice of rejection of the arbitration decision and request for

trial is not made within 20 days of service on the parties of the decision,

the decision must be referred to the presiding judge, who must enter

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such orders and judgments as may be required to carry out the terms of

the decision as provided by section 44.103(5), Florida Statutes.

Fla. R. Civ. P. 1.820(h) (emphasis added).

The Florida Supreme Court also cautioned that, “[u]nder the amended rule, an

arbitration decision will be deemed rejected only if a ‘notice of rejection of the

arbitration decision and request for trial’ is filed with the court within 20 days of

service of the arbitrator’s written decision.” In re Amends. to Fla. R. Civ. P., 386 So.

3d at 878.

This amended rule—and the question of whether a party is entitled to a trial

on the merits when it requests a trial de novo but does not expressly state that it is

providing notice of its rejection of the arbitration decision—was recently the subject

of two cases in Florida’s district courts of appeal: People’s Trust Insurance Co. v.

Hernandez, 413 So. 3d 127 (Fla. 4th DCA 2025), reh’g denied, (May 8, 2025), and

Sanchez v. People’s Trust Insurance Co., 434 So. 3d 155 (Fla. 3d DCA 2026).

The Fourth District decided the issue first. In Hernandez, it found the trial

court erred in denying the insurer’s motion to enforce the non-binding arbitration

decision, because the homeowners’ notice demanding a trial de novo did not also

expressly reject the arbitration decision. 413 So. 3d at 127–28. In doing so, it rejected

the homeowners’ argument that a party cannot request a trial de novo without also

necessarily rejecting the arbitration decision. Id. at 129. Nor was the court persuaded

by the homeowners’ argument that they were entitled to relief because they had

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substantially complied with rule 1.820(h). Id. Instead, the court refused to apply any

substantial compliance test and explained the Florida Supreme Court amended the

rule “to require that a party rejecting the arbitration decision ‘must file a notice of

rejection of the arbitration decision and request for trial in the same document. No

action or inaction by any party, other than the filing of the notice, will be deemed a

rejection of the arbitration decision.’ Fla. R. Civ. P. 1.820(h) (2024) (emphases

added).” Id. That language left no room for “legal wiggling,” as Judge Gross put it.

Id. at 131 (Gross, J., concurring specially).

The Third District likewise considered an argument for substantial

compliance in Sanchez. There, Sanchez argued the trial court erred in entering a final

judgment adopting the arbitrator’s decision because she substantially complied with

the statute and rule, despite failing to include an express notice of rejection of the

arbitrator’s decision. Sanchez, 434 So. 3d at 156. The Third District followed the

Fourth and rejected Sanchez’s argument “[b]ecause rule 1.820(h) requires, without

exception, that a notice of rejection and a motion for trial de novo must be filed

within 20 days of service of the arbitrator’s decision, and Sanchez failed to do so.”

Id. Employing the supremacy-of-text principle, the court rejected Sanchez’s

argument that there could be no doubt as to the purpose of her motion for trial de

novo, because her argument was contrary to the language of the amended rule and

would “render powerless [its] command that ‘[n]o action or inaction by any party,

8

other than the filing of the notice [of rejection], will be deemed a rejection of the

arbitration decision.’” Id. at 158–59 (quoting Fla. R. Civ. P. 1.820(h)). The court

acknowledged rule 1.820(h) was strict but offered that it “is strict for a reason.” Id.

at 158.

Finally, the court concluded that requiring both a request for trial de novo and

a notice of rejection of the arbitrator’s decision is consistent with the plain text of

both the statute and rule. Id. at 159 (citing Koppel v. Ochoa, 243 So. 3d 886, 891

(Fla. 2018) (citation omitted) (“It is well settled that the Florida Rules of Civil

Procedure are construed in accordance with the principles of statutory

construction.”); Nader + Museu I, LLLP v. Miami Dade Coll., 307 So. 3d 140, 142

(Fla. 3d DCA 2020) (holding that two rules of procedure “must be construed in

harmony”); CPI Mfg. Co., Inc. v. Industrias St. Jack’s, S.A. De C.V., 870 So. 2d 89,

92-93 (Fla. 3d DCA 2003) (citations omitted) (“As in statutory construction, the

rules must be read as a cohesive whole, and a rule should not be construed in such a

way as to render another rule meaningless. In addition, a more specific statutory

provision governs over a more general provision.”)).

This Case

As textualists, we agree with the Third District’s use of the supremacy-of-text

principle, along with its application of the canons of statutory construction to guide

its thoughtful analysis. And we acknowledge that these tools are critical when

9

interpreting both the text of section 44.103 and rule 1.820(h). But, in our view, the

application of those principles to the language of rule 1.820(h) and the facts of this

case requires a different result. Consequently, we decline to follow Hernandez and

Sanchez.

Like the Third District, we are guided by the supremacy-of-text principle,

“namely, the principle that ‘[t]he words of a governing text are of paramount

concern, and what they convey, in their context, is what the text means.’” USAA Cas.

Ins. Co. v. Mikrogiannakis, 342 So. 3d 871, 873 (Fla. 5th DCA 2022) (quoting

Forrester v. Sch. Bd. of Sumter Cnty., 316 So. 3d 774, 776 (Fla. 5th DCA 2021)).

And “[w]hen the language of a statute is clear and unambiguous and conveys a clear

and definite meaning, it must be given its plain and obvious meaning.” Id. (quoting

Weightman v. State, 990 So. 2d 590, 592 (Fla. 5th DCA 2008)).

We also consider the goal of interpretation. That goal is to “arrive at a ‘fair

reading’ of the text by ‘determining the application of [the] text to given facts on the

basis of how a reasonable reader, fully competent in the language, would have

understood the text at the time it was issued.’” Lab’y Corp. of Am. v. Davis, 339 So.

3d 318, 323–24 (Fla. 2022) (quoting Ham v. Portfolio Recovery Assocs., LLC, 308

So. 3d 942, 947 (Fla. 2020)). The “fair reading method” considers “the purpose of

the text, ‘gathered only from the text itself, consistently with the other aspects of its

10

context.’” Mikrogiannakis, 342 So. 3d at 874 (quoting Antonin Scalia & Bryan A.

Garner, Reading Law: The Interpretation of Legal Texts 33 (1st ed. 2012)).

It does not, however, “countenance a hyperliteral reading of a legal text.” Id.

(citing Scalia & Garner, Reading Law at 33). Similarly, Justice Scalia has explained

that a “good textualist is not a literalist.” Antonin Scalia, A Matter of Interpretation:

Federal Courts and the Law 24 (Amy Gutmann ed., 1997). Rather, a textualist

knows that “[a] text should not be construed strictly, and it should not be construed

leniently; it should be construed reasonably, to contain all that it fairly means.” Id.

at 23.

In this case, Reynolds defends the trial court’s sua sponte decision to strike

the Association’s motion for trial de novo and urges us that the Association failed to

comply with the amended rule. It argues, “it is without question that [the

Association’s] Request for Trial De Novo did not contain a notice of rejection of the

arbitration decision within it.” And, at oral argument in this case, counsel for

Reynolds argued the Association “had to include that they were rejecting the

arbitration decision” and “needed” the word “rejection” in the notice. That argument

is consistent with the trial court’s finding that “[the document] has to be called a

rejection of the arbitration decision, and a request for trial de novo.”

We decline to adopt this magic-words test. In our view, Reynolds asks us to

interpret the language of rule 1.820(h) in a strict, overly narrow, or hyperliteral way.

11

Consistent with the principles above, however, we must give the words their plain

and obvious meaning, in context, considering the structure of the rule, just as we

would if we were interpreting a statute. See Saia Motor Freight Line, Inc. v. Reid,

930 So. 2d 598, 599 (Fla. 2006) (“It is well settled that the Florida Rules of Civil

Procedure are construed in accordance with the principles of statutory construction.”

(citing Brown v. State, 715 So. 2d 241, 243 (Fla. 1998) (“Our courts have long

recognized that the rules of construction applicable to statutes also apply to the

construction of rules.”))).

In doing so, we first consider the text of rule 1.820(h) as set forth above. The

first sentence of that rule provides: “To reject the arbitration decision, within 20 days

of service of the arbitrator(’s)(s’) written decision, any party must file a notice of

rejection of the arbitration decision and request for trial in the same document.” Fla.

R. Civ. P. 1.820(h). There is no dispute that the Association’s document was timely

filed, or that the document properly contained a request for trial. The parties’ dispute

focuses instead on the requirement that the Association file “a notice of rejection of

the arbitration award.” And so, we examine those words.

First, we find it significant that the rule requires filing a notice, rather than the

notice. As Justice Grosshans recently explained, “the use of an indefinite article,

such as ‘a,’ does not denote a specific noun, but merely a member of a class.” Brito

v. Salas, 434 So. 3d 39, 48 (Fla. 2025) (citing Myers v. State, 696 So. 2d 893, 900

12

(Fla. 4th DCA 1997), quashed on other grounds, 713 So. 2d 1013 (Fla. 1998); State

v. Crose, 378 So. 3d 1217, 1237 (Fla. 2d DCA 2024) (“A or an goes before a word

or phrase denoting a person or thing (noun) but not a specific one. . . .” (quoting Paul

W. Lovinger, The Penguin Dictionary of American English Usage and Style 1, 426

(2000)))). Conversely, “grammar and usage establish that ‘the’ is ‘a function word .

. . indicat[ing] that a following noun or noun equivalent is definite or has been

previously specified by context.’” Nielsen v. Preap, 586 U.S. 392, 408 (2019)

(quoting Merriam-Webster’s Collegiate Dictionary 1294 (11th ed. 2005)); see also

Work v. United States ex rel. McAlester-Edwards Co., 262 U.S. 200, 208 (1923)

(Congress’s “use of the definite article [in a reference to “the appraisement”] means

an appraisement specifically provided for”); Myers, 696 So. 2d at 900 (“[T]he

definite article, ‘the’ . . . before a noun specifies a definite and specific noun, as

opposed to any member of a class.”).

The Florida Supreme Court’s use of the indefinite article before the word

“notice” supports the argument that no specific form of notice is required. Sure, the

notice has to do a particular thing—provide notice of rejection of the arbitration

decision—but the use of the indefinite article cuts against Reynolds’s claim that a

specific notice containing the precise words “notice of rejection” are required. We

note, too, that the words “notice of rejection” are not in quotation marks within the

rule, or even capitalized. See Fla. R. Civ. P. 1.820(h).

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Because no specific or previously identified notice of rejection is required,

and because the rule does not define or announce what it means by a “notice of

rejection,” we look to the dictionary definition of the words to discern their plain and

ordinary meaning. Black’s Law Dictionary defines “notice” as a “[l]egal notification

required by law or agreement,” the “condition of being so notified, whether or not

actual awareness exists,” or a “written or printed announcement.” Notice, Black’s

Law Dictionary (12th ed. 2024). It defines “rejection” as a “refusal to accept a

contractual offer.” Rejection, Black’s Law Dictionary (12th ed. 2024). Here, the

Association’s filing was a written or printed document that announced the

Association wanted a trial de novo “from the Non-Binding Arbitration Award dated

September 24, 2024, as to all claims.” That language provided notice that the

Association refused to accept the non-binding arbitration decision. We can see no

other way to read that language, and tellingly, Reynolds offers no other interpretation

for our consideration.

Rather, Reynolds glosses over the language of the document and insists

nothing short of the words “notice of rejection” will do. It argues that, because the

Association’s filing does not contain that express language, it was properly stricken

under rule 1.820(h). But that’s not how we interpret legal texts. See Scalia, A Matter

of Interpretation: Federal Courts and the Law at 23 (“[A] text should not be

construed strictly, and it should not be construed leniently; it should be construed

14

reasonably, to contain all that it fairly means.”); Smith v. Smith, 224 So. 3d 740, 754

(Fla. 2017) (Polston, J., dissenting) (“[C]onstruing the plain meaning of a statute is

not a magic words test.”); Spurlock v. State, 420 So. 2d 875, 877 (Fla. 1982)

(considering whether petitioner’s objection satisfied Florida Rule of Criminal

Procedure 3.390(d) and finding “[t]he missing ‘magic words’ do not concern us

because the necessary substance was present”).

When we construe the words “notice of rejection of the arbitration decision”

reasonably, to contain all that the words fairly mean, we conclude that filing a

document under rule 1.820(h) and section 44.103—that provides notice that the

Association is requesting a trial de novo, challenging a particular arbitration award—

satisfies that requirement. To interpret it as Reynolds suggests would be to exalt

form over substance and to narrowly construe the words to mean less than what they

fairly mean.

Our consideration of this text in context also requires us to face the following

sentence and consider its impact on the language at issue: “No action or inaction by

any party, other than the filing of the notice, will be deemed a rejection of the

arbitration decision.” Fla. R. Civ. P. 1.820(h). While we acknowledge the language

in that sentence is mandatory and straightforward, we have already found that the

document in this case constituted the required notice. The Association is not relying

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on any “other action or inaction” to satisfy rule 1.820(h). That sentence, therefore,

does not change the outcome here.

It does, however, compel us to explain that, in interpreting rule 1.820(h) in

this way, we do not revive the concept of “substantial compliance” rejected by recent

cases interpreting rule 1.820(h). Those substantial compliance cases routinely

resolved the question of whether one party requested a trial de novo based on that

party’s conduct, not the sufficiency of a document expressly filed under rule

1.820(h) and section 44.103.

For example, in Nicholson-Kenny Capital Management, Inc. v. Steinberg, the

Fourth District reversed a final judgment on an arbitration award, even though the

appellant never filed a motion for trial as required by rule 1.820, because the

appellant filed a notice to set the pretrial conference, in accordance with the order

setting trial, and appellees’ “words, actions, and conduct led [appellant] to believe

that they assented to its request for a trial de novo.” 932 So. 2d 321, 322–23, 326

(Fla. 4th DCA 2006).

Similarly, in de Acosta v. Naples Community Hospital, Inc., the Second

District found the appellant substantially complied with the requirement for moving

for a trial de novo and reversed the final judgment. 300 So. 3d 264, 265 (Fla. 2d

DCA 2019). Although the court acknowledged the appellant did not “technically

comply” with rule 1.820(h), it nonetheless concluded appellant’s identification of

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disputed facts and an issue of law contained in a pending motion in limine somehow

satisfied rule 1.820(h). Id. at 267.

The Second District did this again in Beyond Billing, Inc. v. Spine &

Orthopedic Center, P.C., 362 So. 3d 256 (Fla. 2d DCA 2023). There, it denied a

petition for writ of mandamus, asking the court to compel the circuit court to enter a

final judgment on the arbitration award. Id. at 257. The court denied that request, not

based on the language of the rule, but because “the parties indicated a mutual

intention to proceed to trial by executing a joint stipulated motion to amend the case

management order.” Id. at 257–58. It justified that decision by relying on what it

believed to be the “purpose” of rule 1.820(h). See id. at 258 (“The purpose of filing

a motion for trial under rule 1.820 is to give the other side ‘notice that it should be

prepared for trial.’”).

This case is unlike Nicholson-Kenny, de Acosta, and Beyond Billing. Our

focus is not on the conduct of any party or the nature of other documents filed

pursuant to other rules and court orders. Rather, our conclusion flows from the plain

language of rule 1.820(h) and a consideration of whether the statements made in a

document timely and expressly filed under section 44.103 and rule 1.820(h)

constituted a notice of the Association’s rejection of the arbitration decision and a

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request for trial. Neither Nicholson-Kenny, de Acosta, nor Beyond Billing considered

such a document or tracked the plain language of the rule.2

Finally, we note there can be no doubt the Association complied with section

44.103(5). That subsection instructs that an arbitration decision “shall be final if a

request for a trial de novo is not filed within the time provided by rules promulgated

by the Supreme Court.” The Association filed a request for trial de novo within

twenty days, and “nothing” in the statute suggests that “the trial court has the

discretion to deny a party’s timely motion for trial” after arbitration. Dungarani, 312

So. 3d at 131. Thus, under the statute, the Association was entitled to a trial de novo.

Insofar as the rule may have required something additional from the

Association notwithstanding its compliance with the statute, we note that “[a]

procedural rule should not be strictly construed to defeat a statute it is designed to

2

Interestingly, the Fourth District did find substantial compliance with the prior version of rule 1.820(h) based on the language of a timely motion for trial de novo in Vitesse, Inc. v. MAPL Associates LLC, 358 So. 3d 437, 440 (Fla. 4th DCA 2023), and the Hernandez court reaffirmed that holding. See Hernandez, 413 So. 3d at 131. Vitesse relied on Nicholson-Kenny and explained “the intention of rule 1.820(h) is to send ‘some notice to the opposing party that its adversary is rejecting an arbitration award and renewing its demand for trial.’” Vitesse, Inc., 358 So. 3d at 439 (citing Nicholson-Kenny, 932 So. 2d at 324). And in finding the motion substantially complied with the prior version of rule 1.820(h), the Vitesse court reasoned: “[A]ny scrivener’s error in the operative motion was trivial and did not substantially impair either appellee or the lower court from having reasonable notice of [the] appellants’ desire to proceed to trial.” Id. at 440.

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implement.” Kuhajda v. Borden Dairy Co. of Ala., LLC., 202 So. 3d 391, 396 (Fla.

2016). The procedural “tail” should not be allowed to wag the substantive “dog.” Id.

CONCLUSION

Because the Association complied with the requirements of section 44.103(5)

and rule 1.820(h), we find the trial court erred in sua sponte striking its motion and

request for trial de novo. We therefore reverse the final judgment confirming the

non-binding arbitration award and remand for proceedings consistent with this

opinion, after the issuance of our mandate. Finally, we certify conflict with People’s

Trust Insurance Co. v. Hernandez, 413 So. 3d 127 (Fla. 4th DCA 2025), reh’g

denied, (May 8, 2025), and Sanchez v. People’s Trust Insurance Co., 434 So. 3d 155

(Fla. 3d DCA 2026).

REVERSED and REMANDED with instructions.

SMITH, J., concurs.

PRATT, J., concurs with opinion.

NOT FINAL UNTIL TIME EXPIRES TO FILE MOTION FOR REHEARING

AND DISP OSITION THEREOF IF TIMELY FILED

PRATT, J., concurring.

I fully concur in the majority’s decision. I write separately to emphasize that

our reading of Florida Rule of Civil Procedure 1.820(h) has two benefits. First, it is

consistent with a fair reading of the text of the rule and the text of section 44.103(5),

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Florida Statutes. And second, it avoids unnecessarily reading the text of the rule as

containing a requirement that does not implement a substantive requirement of the

text of the statute. That being said, if we were to read the text of the rule as containing

a requirement that does not implement a substantive requirement of the text of the

statute, we would be required to give effect to the statute’s substantive requirement

and excuse noncompliance with the rule’s non-implementing requirement. See

generally, e.g., Trace Elements, Inc. v. Mackensen, 51 Fla. L. Weekly S197c, 2026

WL 1901612, at *4 (Fla. July 2, 2026); Kuhajda v. Borden Dairy Co. of Ala., LLC,

202 So. 3d 391, 395-96 (Fla. 2016).

Lenore T. Brakefield, F. Scott Pauzar, III, and Cameron G. Woodward, of Woodward, Pires, & Lombardo, P.A., Naples, for Appellant.

Lori L. Moore, of Roetzel & Andress, LPA, Fort Myers, for Appellee.

20