A to Z Properties, Inc. v. Fairway Palms II Condominium Ass'n, 137 So. 3d 453

A to Z Properties, Inc. purchased a condominium unit at a tax sale in October 2010 and received a tax deed; prior owners had $16,291.61 in unpaid condominium assessments at that time.
About two weeks later A to Z sold the unit to Rafael Charre‑Sanchez for $30,000.
The condominium association recorded a lien in February 2011 for the unpaid assessments and sued A to Z and Sanchez seeking foreclosure and money judgments for unpaid assessments.
The parties stipulated to material facts and cross‑moved for partial summary judgment on whether unpaid assessments accruing before acquisition survived the tax deed.
The trial court held A to Z liable under Fla. Stat. § 718.116(1)(a); A to Z appealed arguing Fla. Stat. ch. 197 (tax deed statutes) extinguished preexisting assessment liabilities.

Issue	Plaintiff's Argument	Defendant's Argument	Held
Do unpaid condominium assessments that accrued before a tax deed survive the issuance of the tax deed?	Association: § 718.116(1)(a) makes a unit owner jointly and severally liable with prior owner for unpaid assessments up to transfer of title.	A to Z: Chapter 197 (esp. § 197.552 and § 197.573(2)) extinguishes covenants creating debts or liens upon issuance of a tax deed; acquisition by tax deed creates a new title, not a transfer.	Reversed: Chapter 197 controls; liens and obligations creating debts that predate a tax deed are extinguished and do not survive issuance of the tax deed.

Major League Baseball v. Morsani, 790 So.2d 1071 (Fla. 2001) (standard of review for legal questions on summary judgment is de novo)
Cricket Props., LLC v. Nassau Pointe at Heritage Isles Homeowners Ass’n, Inc., 124 So.3d 302 (Fla. 2d DCA 2013) (tax deed statutes extinguish covenants creating debts or liens that predate the tax deed)