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Janet L. Schmidt v. Stokes McMillan Antúnez Martinez-Lejarza P.A.

2026-08-26

Summary

Holding. The court affirmed the trial court's dismissal because Florida Statutes chapter 682 expressly requires that when a civil action involving an arbitration agreement is pending, a motion to vacate an arbitration award must be filed in that pending action, not in a separate lawsuit.

The appellants sought to vacate an arbitration award in a separate lawsuit filed in a different division of the trial court, rather than by motion in the original pending action where the arbitration clause was at issue. The trial court dismissed this second action with prejudice. The appellate court affirmed, holding that Florida's arbitration statute expressly requires that a party seeking to vacate an arbitration award must do so by motion in any pending civil action involving the arbitration agreement, not by filing a separate lawsuit. Allowing separate lawsuits would create inefficiency and risk inconsistent judicial outcomes.

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

Key issues

  • Whether a party may file a separate lawsuit to vacate an arbitration award when a related civil action is pending
  • Proper procedural mechanism for seeking vacatur of an arbitration award under Florida law
  • Application of Florida Statutes chapter 682 to arbitration disputes

Procedural posture

The appellants appealed a trial court order dismissing their lawsuit to vacate an arbitration award, which was entered after the trial court confirmed the award in a separately pending declaratory judgment action.

Authorities cited

No cited authorities resolved to law.co cases yet.

Opinion

majority opinion

Third District Court of Appeal

State of Florida

Opinion filed August 26, 2026.

Not final until disposition of timely filed motion for rehearing.

No. 3D25-1221

Lower Tribunal No. 24-21577-CA-01

Janet L. Schmidt, et al.,

Appellants,

vs.

Stokes McMillan Antúnez Martinez-Lejarza P.A.,

Appellee.

An Appeal from the Circuit Court for Miami-Dade County, Abby Cynamon, Judge.

Janet L. Schmidt (Dagsboro, DE), for appellants.

Stokes McMillan Antúnez Martinez-Lejarza P.A., and Kimberly A. Martinez-Lejarza, for appellee.

Before SCALES, C.J., and FERNANDEZ and LOBREE, JJ.

ON MOTION FOR CLARIFICATION

SCALES, C.J.

We grant appellants’ motion for clarification, withdraw our opinion filed

on July 22, 2026, and substitute the following opinion in its place.

Appellants,1 the plaintiffs below, appeal a May 28, 2025 final order

dismissing with prejudice their lawsuit to vacate an arbitration award entered

in favor of appellee, the defendant below, Stokes McMillan Antúnez

Martinez-Lejarza P.A. We affirm because the statutory scheme governing

confirmation, modification, correction or vacatur of arbitration awards –

codified in chapter 682, Florida Statutes – expressly requires that vacatur be

sought by motion when, as here, a lawsuit involving the agreement to

arbitrate remains pending. See § 682.015(2), Fla. Stat. (2024) (“Unless a

civil action involving the agreement to arbitrate is pending, notice of an initial

petition to the court under this chapter must be served in the manner

provided by law for the service of a summons in a civil action. Otherwise,

notice of the motion must be given in the manner provided by law or rule of

court for serving motions in pending cases.”); § 682.13(1), Fla. Stat. (2024)

(providing the means for vacating an arbitration award “[u]pon motion of a

party to an arbitration proceeding”).

1

Appellants are Janet L. Schmidt, individually, and John R. Fernstrom, as Trustee of the Whiteacre Asset Trust. Ms. Schmidt is a member of the Florida Bar and is representing both herself and Trustee Fernstrom.

2

Appellee is a law firm that represented Appellants in prior, unrelated

litigation. The parties’ retainer agreement contained an arbitration clause

requiring that any dispute over attorney’s fees be resolved in an arbitration

proceeding before the American Arbitration Association. A dispute over

attorney’s fees arose and Appellee initiated an arbitration proceeding.

In April 2023, Appellants filed a declaratory judgment action (“Initial

Action”)2 below seeking to invalidate the arbitration clause in the parties’

retainer agreement. In November 2023, the trial court in the Initial Action

entered an order compelling arbitration, staying the litigation and reserving

jurisdiction to enforce the arbitration panel’s arbitration award (“Arbitration

Order”). Appellants appealed the Arbitration Order to this Court (appellate

case number 3D23-1996).

While 3D23-1996 was still pending in this Court, on August 15, 2024,

the arbitration panel rendered an arbitration award in Appellee’s favor.

Appellants did not file a motion to vacate the arbitration award in the Initial

Action, as expressly required by section 682.015(2) of the Florida Statutes.

Instead, Appellants filed, in a different division of the Miami-Dade County

Circuit Court, the instant action to vacate the arbitration award (“Second

Action”).

2

The Initial Action is lower tribunal case number 2023-15113-CA-01.

3

On February 19, 2025, in 3D23-1996, this Court affirmed the

Arbitration Order. See Schmidt v. Stokes McMillan Antúnez MartinezLejarza, P.A., 406 So. 3d 968 (Fla. 3d DCA 2025). The Second Action was

then transferred to the trial judge presiding over the Initial Action. After the

issuance of our mandate in 3D23-1996, Appellee filed a motion in the Initial

Action seeking to confirm the arbitration award. See § 682.12, Fla. Stat.

(2024) (“After a party to an arbitration proceeding receives notice of an

award, the party may make a motion to the court for an order confirming the

award at which time the court shall issue a confirming order unless the award

is modified or corrected pursuant to s. 682.10 or s. 682.14 or is vacated

pursuant to s. 682.13.”).

The trial court entered a judgment in the Initial Action confirming the

arbitration award.3 The trial court then dismissed the Second Action with

prejudice, and it is from this May 28, 2025 order dismissing the Second

Action that Appellants now appeal.

We affirm the trial court’s dismissal order because where, as here,

there is a pending civil action involving the parties’ agreement to arbitrate,

chapter 682’s express statutory scheme requires a motion to vacate the

3

Appellants have appealed the confirmation judgment, and that appeal (appellate case number 3D25-2345) remains pending in this Court.

4

arbitration award be filed in the pending action. See § 682.015(2), Fla. Stat.

(2024); §682.13(1), Fla. Stat. (2024). Allowing multiple, separate lawsuits is

violative of chapter 682 and risks not only unnecessary duplicative judicial

resources, but also the possibility of inconsistent results.

Affirmed.

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