Grand Central at Kennedy Condominium Association, Inc. v. Space Coast Credit Union
173 So. 3d 1089
| Fla. Dist. Ct. App. | 2015Background
- Space Coast obtained a final judgment of foreclosure against Robert Hayden and later purchased the condominium unit at foreclosure sale.
- Grand Central Condominium Association assessed unpaid condominium fees against Space Coast after the sale.
- One year after the final judgment, Space Coast moved to enforce the judgment or amend the certificate of title to determine and limit its liability for unpaid assessments under section 718.116(1)(b) (the 12‑month/1% safe harbor).
- Grand Central opposed, arguing the trial court lacked jurisdiction because the final judgment did not adjudicate assessments and only contained a general reservation of jurisdiction.
- The trial court granted Space Coast’s motion and applied the statutory limitation; the condominium association appealed.
- The Second District reversed, holding the trial court lacked postjudgment jurisdiction to determine assessment amounts because entitlement to assessments had not been litigated or specifically reserved in the final judgment.
Issues
| Issue | Plaintiff's Argument | Defendant's Argument | Held |
|---|---|---|---|
| Whether trial court had jurisdiction postjudgment to determine unpaid condominium assessments under §718.116(1)(b) | Space Coast: court retained inherent/postjudgment authority to enforce the judgment and thus could determine and limit assessment liability | Grand Central: final judgment did not adjudicate assessments and only included a general reservation of jurisdiction, so court lacked jurisdiction | Court held no jurisdiction: entitlement to assessments was neither litigated nor specifically reserved, so postjudgment relief was improper |
Key Cases Cited
- Cent. Mortg. Co. v. Callahan, 155 So. 3d 373 (Fla. 3d DCA 2014) (trial court lacks postjudgment jurisdiction to determine assessments where final judgment only generally reserves jurisdiction)
- Montreux at Deerwood Lake Condo. Ass'n v. Citibank, N.A., 153 So. 3d 961 (Fla. 1st DCA 2014) (no assessment‑related judgment existed to be enforced; trial court lacked jurisdiction)
- Ross v. Damas, 31 So. 3d 201 (Fla. 3d DCA 2010) (court loses jurisdiction after final judgment and time to alter/modify unless jurisdiction is specifically reserved)
- Ross v. Wells Fargo Bank, 114 So. 3d 256 (Fla. 3d DCA 2013) (same principle: final judgments generally terminate trial court jurisdiction absent specific reservation or statutory authority)