• Quiet title: trial court lacked jurisdiction to extinguish easement on property in quiet title action where only relief sought in complaint was to confirm title to the property - Keys Island Props., LLC v. Crowe, No. 3D12-360 (Fla. 3d DCA September 19, 2012) (reversing final judgment)
  • Attorney Fees: section 57.105(7) allows mortgagor to recover attorneys’ fees from mortgagee when foreclosure action is involuntarily dismissed; however, mortgagor is not entitled to fees if sufficient evidence to establish reasonableness of fees is not presented at the original hearing. mortgagor is not entitled to a second hearing to produce evidence to support award of fees after court denied fees in first hearing – Raza v. Deutsch Bank, No. 2D11-4505 (Fla. 2d DCA September 21, 2012) (affirming denial of attorneys’ fees)
  • Standing: transfer of mortgage years after foreclosure complaint was filed is irrelevant for purpose of determining standing at the time foreclosure commenced because note or other debt secured by the mortgage could have been transferred without formal assignment and mortgage follows the debt – Cutler v. US Bank N.A., No. 2D10-5709 (Fla. 2d DCA September 21, 2012) (reversed and remanded)