Anamaria Santiago v. Mauna Loa Investments, LLC.
189 So. 3d 752
| Fla. | 2016Background
- Santiago sued Mauna Loa for premises liability after tripping on a warehouse walkway on July 2, 2008; Mauna was served but failed to answer and a default was entered in May 2010.
- Santiago later filed a separate complaint against Iberia, NV, alleging Iberia (not Mauna) owned the property; that Iberia complaint included a special warranty deed showing transfer to Mauna occurred after the injury.
- The Iberia action was later consolidated with the Mauna case for a time; Santiago subsequently voluntarily dismissed the Iberia complaint.
- Mauna repeatedly sought to set aside the default, attaching the Iberia complaint and deed, arguing Mauna did not own or control the property at the time of injury; the trial court denied relief and barred further motions.
- After a damages-only trial, the jury awarded Santiago about $1.1 million; the Third District reversed, holding the Mauna complaint failed to state a claim because the Iberia complaint and deed showed Mauna did not own the property.
- The Florida Supreme Court granted review, held the Third District erred by considering a separate complaint outside the four corners of the Mauna complaint, affirmed the trial court’s denial of Mauna’s motion to set aside the default (finding no excusable neglect), and quashed the district court decision.
Issues
| Issue | Plaintiff's Argument | Defendant's Argument | Held |
|---|---|---|---|
| Whether a court determining sufficiency of a complaint may consider separate, non‑attached pleadings/documents filed in other cases | Santiago: sufficiency must be judged from the complaint and its attachments only (four‑corners rule) | Mauna: trial court could consider the consolidated Iberia complaint and attached warranty deed showing Mauna lacked ownership/control | Court: Review is limited to the complaint and its attachments; district court erred by considering a separate complaint and deed outside the Mauna complaint’s four corners |
| Whether judgment based on a complaint that fails to state a cause of action is void, obviating excusable‑neglect inquiry for vacating default | Santiago: judgment based on a defective complaint is not necessarily void; vacatur still requires excusable neglect/diligence/meritorious defense | Mauna: default judgment is void if complaint fails to state a cause of action and thus relief can be granted without showing excusable neglect | Court: A judgment based on a complaint that fails to state a cause of action is voidable, not automatically void; Mauna failed to show excusable neglect, so denial of set‑aside was proper |
Key Cases Cited
- Pizzi v. Central Bank & Trust Co., 250 So. 2d 895 (Fla. 1971) (adopts the four‑corners rule: sufficiency of a complaint is judged solely from the complaint and its attachments)
- Paladin Properties v. Family Investment Enterp., 952 So. 2d 560 (Fla. 2d DCA 2007) (exhibits attached to a complaint become part of the pleading and can control when they clearly contradict the complaint; exhibits must negate the cause of action to support dismissal)
- Rhodes v. O. Turner & Co., 117 So. 3d 872 (Fla. 4th DCA 2013) (applied four‑corners review and reversed vacation of default where complaint on its face stated a cause of action)
- Abel, Tony & Aldo Creative Group, Inc. v. Friday Night Investors, Inc., 419 So. 2d 1135 (Fla. 3d DCA 1982) (defendant’s mere belief that counsel responded is insufficient to establish excusable neglect to vacate a default)