CAM Bradford Homes, LLC v. Wayne Arrants and Berkely Arrants
5D2024-0849
| Fla. Dist. Ct. App. | Jun 20, 2025Background
- Wayne and Berkely Arrants (Appellees) hired CAM Bradford Homes, LLC (Appellant), an LLC owned by Cameron Bradford, to build a home in Florida in December 2020.
- Although Bradford was a certified general contractor, the LLC itself was never registered or certified with the Florida Department of Business and Professional Regulation as required by law.
- Construction was terminated by the Arrants before completion. CAM Bradford Homes, LLC filed suit for breach of contract and other related claims.
- The Arrants argued that the LLC was unlicensed and thus could not enforce the contract under Florida law.
- The trial court granted summary judgment for the Arrants, finding the LLC unlicensed and its contract unenforceable.
- CAM Bradford Homes, LLC appealed the decision.
Issues
| Issue | Plaintiff's Argument | Defendant's Argument | Held |
|---|---|---|---|
| Whether the LLC could enforce the contract as a contractor | Bradford’s license as an individual sufficed to qualify LLC | LLC never registered or had a qualifying agent with the state | LLC was unlicensed and could not enforce the contract |
| Does performing tasks of a qualifying agent satisfy statute | Bradford performed all qualifying agent duties for LLC | Statute requires formal application/registration, not just acts | Performing duties alone is not enough; proper application is mandatory |
| Applicability of statutory exceptions | Not argued or applicable | Statutory exception does not apply | Exceptions not relevant; statutory requirements control |
| Tortious interference claim preserved for appeal | Argued it should survive despite unenforceable contract | Issue was unpreserved | Unpreserved issue; not considered on appeal |
Key Cases Cited
- Palm Beach Resurfacing, Inc. v. Floyd, 401 So. 3d 359 (Fla. 4th DCA 2025) (summary judgment standard and statutory interpretation reviewed de novo)
- Taylor Morrison Servs., Inc. v. Ecos, 163 So. 3d 1286 (Fla. 1st DCA 2015) (statutory construction and importance of harmonizing statutes)
- Scherer v. Volusia Cnty. Dept of Corr., 171 So. 3d 135 (Fla. 1st DCA 2015) (no part of a statute should be rendered meaningless)
- Tsuji v. Fleet, 366 So. 3d 1020 (Fla. 2023) (significance and effect must be given to every word of a statute)