HomeMy WebLinkAboutSubmittal-Eddy Leal-Initial Brief of AppellantFiling # 168439019 E-Filed 03/09/2023 10:57:29 PM
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IN THE THIRD DISTRICT COURT OF APPEAL
STATE OF FLORIDA
CASE NO. 3D22-1897
CITY OF MIAMI,
Appellant,
-vs-
1000 BRICKELL, LTD.,
Appellee.
AN APPEAL FROM THE CIRCUIT COURT OF THE
ELEVENTH JUDICIAL CIRCUIT OF FLORIDA
IN AND FOR MIAMI-DADE COUNTY
INITIAL BRIEF OF APPELLANT
VICTORIA MENDEZ, City Attorney
ERIC J. EVES, Assistant City Attorney
Attorneys for Appellant
444 S.W. 2nd Avenue, Suite 945
Miami, Florida 33130-1910
Phone: (305) 416-1800
Primary Email: eeves@miamigov.com
Secondary Email: csantos@miamigov.com
14278-Submittal-Eddy Leal -Initial Brief of Appellant
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TABLE OF CONTENTS
TABLE OF CONTENTS
TABLE OF CITATIONS iii
STATEMENT OF THE CASE AND FACTS 1
STANDARD OF REVIEW 9
SUMMARY OF THE ARGUMENT 10
ARGUMENT 12
I. THE TRIAL COURT ERRED IN DENYING THE CITY'S MOTION
FOR FINAL SUMMARY JUDGMENT BECAUSE THE FIVE-YEAR
STATUTE OF LIMITATIONS BARS 1000 BRICKELL'S CAUSES
OF ACTION 12
A. 1000 Brickell filed the original complaint more than five years
after its causes of action accrued 13
B. The continuing breach doctrine does not apply 15
C. Even if 1000 Brickell filed the original complaint within the
statute of limitations, it filed the operative complaint, which
does not relate back to the original complaint, outside the
statute of limitations 22
II. THE TRIAL COURT ERRED IN GRANTING 1000 BRICKELL'S
MOTION FOR FINAL SUMMARY JUDGMENT BECAUSE
GENIUNE DISPUTES AS TO MATERIAL FACTS EXIST OR 1000
BRICKELL IS NOT ENTITLED TO JUDGMENT AS A MATTER
OF LAW 28
A. 1000 Brickell is not entitled to summary judgment on the
issue of forfeiture 30
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B. If the City is not entitled to summary judgment on the issue
of the statute of limitations, 1000 Brickell is not entitled to
summary judgment on the issue 33
C. 1000 Brickell is not entitled to summary judgment on the
issue of waiver 35
CONCLUSION 38
CERTIFICATE OF SERVICE 39
CERTIFICATE OF COMPLIANCE 40
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TABLE OF CITATIONS
Cases
1000 Brickell, Ltd. v. City of Miami,
339 So. 3d 1091 (Fla. 3d DCA 2022) 7, 8
Antioch Univ. v. State, Dep't of Nat.,
647 So. 2d 915 (Fla. 4th DCA 1994) 31
Aristide v. Jackson Mem'l Hosp.,
917 So. 2d 253 (Fla. 3d- DCA -2005)---
16
Blumberg v. USAA Cas. Ins. Co.,
790 So. 2d 1061 (Fla. 2001) 13
Brevard Cnty. v. Waters Mark Dev. Enterprises, LC,
350 So. 3d 395 (Fla. 5th DCA 2022) 9, 28
Castro v. Linfante,
307 So. 3d 110 (Fla. 3d DCA 2020) 23
City of Quincy v. Womack,
60 So. 3d 1076 (Fla. 1st DCA 2011) 19
City of Riviera Beach v. Reed,
987 So. 2d 168 (Fla. 4th DCA 2008) 12, 14
Dade Cty. v. City of N. Miami Beach,
69 So. 2d 780 (Fla. 1953) 30, 33
Delgado v. Agency for Health Care Admin.,
237 So. 3d 432 (Fla. 1st DCA 2018) 13
Delivorias v. Delivorias,
80 So. 3d 352 (Fla. 1st DCA 2011) 6
Fed. Ins. Co. v. Sw. Florida Ret. Ctr., Inc.,
707 So. 2d 1119 (Fla. 1998) 12, 27, 34
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Floyd v. State (In re Forfeiture of: £1992 Pontiac Firebird No.
1G2FS23T3NL212004),
47 So. 3d 344 (Fla. 2d DCA 2010) 26
Grove Isle Ass'n, Inc. v. Grove Isle Associates, LLLP,
137 So. 3d 1081 (Fla. 3d DCA 2014) 19, 20
Hanna v. Sunrise Recreation, Inc.,
94 So. 2d 597 (Fla. 1957) 32
Hunt v. State,
613 So. 2d 893 (Fla: 1992).......... ..... .. .............. 6
Jacksonville Transp. Auth. v. Cont'l Equities, Inc.,
636 So. 2d 1354 (Fla. 1st DCA 1994) 16, 17, 21
Kopel v. Kopel,
229 So. 3d 812 (Fla. 2017) 23, 24, 25
Med. Jet, S.A. v. Signature Flight Support -Palm Beach, Inc.,
941 So. 2d 576 (Fla. 4th DCA 2006) 13, 27, 34
Palm Beach Cnty. Sch. Bd. v. Doe,
210 So. 3d 41 (Fla. 2017) 23
Pearson v. Ford Motor r Co.,
694 So. 2d 61 (Fla. 1st DCA 1997) 35
Perez-Gurri Corp. v. McLeod,
238 So. 3d 347 (Fla. 3d DCA 2017) 29
Pol v. Pol,
705 So. 2d 51 (Fla. 3d DCA 1997) 18, 20
Popular Bank of Florida v. R.C. Asesores Financieros, C.A.,
797 So. 2d 614 (Fla. 3d DCA 2001) 35
Roschman Partners v. S.K. Partners I, Ltd.,
627 So. 2d 2 (Fla. 4th DCA 1993) 36
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Russell v. Williams,
964 P.2d 231 (Okla. Civ. App. 1998) 19
Sch. Bd. of Broward Cty. v. Surette,
394 So. 2d 147 (Fla. 4th DCA 1981) 23
Shands v. City of Marathon,
261 So. 3d 750 (Fla. 3d DCA 2019) 29
Simmons v. Pub. Health Tr. of Miami -Dade Cnty.,
338 So. 3d 1057 (Fla. 3d DCA 2022) 9
Spitzer v. Bartlett Bros. Roofing,
437 So. 2d 758 (Fla. 1st DCA 1983) 13
State Farm Mut. Auto. Ins. Co. v. Lee,
678 So. 2d 818 (Fla. 1996) Passim
Tiffany Realty, Inc. v. Alvin,
311 So. 2d 832 (Fla. 3d DCA 1975) 30, 33
Torres v. K-Site 500 Assocs.,
632 So. 2d 110 (Fla. 3d DCA 1994) 30, 33, 35, 37
Universal Med. Inv. Corp. v. Mike Rollison Fence, LLC,
331 So. 3d 242 (Fla. 1st DCA 2021) 18, 20
Viera v. City of Lake Worth, Florida,
230 So. 3d 484 (Fla. 4th DCA 2017) 16, 19
Walgreen Co. v. Habitat Dev. Corp.,
655 So. 2d 164 (Fla. 3d DCA 1995) 18, 20
White v. Metro. Dade Cty.,
563 So. 2d 117 (Fla. 3d DCA 1990) 30, 31, 33
Winn -Dixie Stores, Inc. v. Dolgencorp, LLC,
746 F.3d 1008 (11th Cir. 2014) 15, 18, 19, 20
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XP Glob., Inc. v. AVM, L.P., 16-CV-80905, 2016 WL 4987618, at *3-
4 (S.D. Fla. Sept. 19, 2016) 19
Statutes
§ 95.031, Fla. Stat 12, 14
§ 95.11, Fla. Stat 4, 5, 12
§ 95.36, Fla. Stat 4, 5, 6, 7, 13
Rules
Fla. R. Civ. P. 1.110 38
Fla. R. Civ. P. 1.190 23
Fla. R. Civ. P. 1.510 9
Fla. R. App. P. 9.045 40
Fla. R. App. P. 9.210 40
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STATEMENT OF THE CASE AND FACTS
In 1974, a grantor conveyed property to the City of Miami
through a warranty deed. (R. 2383-84). The property includes two
parcels of land: a north parcel and a south parcel. Id. The warranty
deed included a reverter provision governing both parcels:
TO HAVE AND TO HOLD, the same in fee simple forever;
provided however, -that--if any part of the property herein
conveyed shall ever be used for any purpose other than
public park purposes, the estate hereby granted to the
grantee shall automatically and immediately terminate,
and all right, title and interest in and to such property
shall thereupon revert to the grantor.
Id. After the property was donated to the City, it was used as a public
park. (R. 1794).
In 1999, the managing partner of the grantor's successor in
interest, 1000 Brickell, Ltd. (hereinafter, "1000 Brickell"), wrote a
letter to the City. (R. 744-45). He urged the City to allow a commercial
use of the north parcel of the property for La Cucina Management,
Inc., d/b/a Perricone's Marketplace (hereinafter, "the restaurant").
Id.
The same year, the City and 1000 Brickell entered into a
consent agreement. (R. 2386-87). The consent agreement permitted
the City to enter into a revocable license agreement with the
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restaurant. Id. It also permitted the restaurant to use a portion of the
north parcel of the property (1,144 square feet) "for the installation
of new ground level seating, and providing food and beverage service
to its patrons as well as for the benefit of the general public." Id.
In 2000, the restaurant installed a structure that exceeded the
1,144 square feet provided for in the consent agreement. (R. 2483,
2821-22, 2829, 2851). In 2007, the restaurant expanded its
structure again. (R. 2492-95). By 2009, Perricone's Marketplace
finished construction on a new structure. (R. 2532). By 2012, the
restaurant's footprint exceeded 3,000 square feet. (R. 2500).
From 1999 to 2013, while the restaurant expanded its
operations, 1000 Brickell's managing partner regularly visited the
restaurant. (R. 893-94). He expressly approved of the expanded
operations. (R. 894). After a falling out with the restaurant's owner,
which led to litigation between 1000 Brickell and the restaurant,
1000 Brickell's managing partner stopped visiting the restaurant. (R.
893-94).
In 2014, 1000 Brickell and another plaintiff, who is not a party
to these appellate proceedings, filed the original complaint against
the City. (R. 31) . 1000 Brickell alleged a violation of the warranty deed
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on the south parcel of the property only. (R. 31-40) . It sought to
enjoin the City from conveying the south parcel to a private entity
(Brickell Flatiron, LLC) . (R. 36) . The original complaint had nothing
to do with the north parcel of the property, the consent agreement,
or the restaurant on the north parcel of the property (or any other
restaurant) . (R. 31-40) .
In 2018, 1000 Brickell filed the amended complaint. (R. 116). It
alleged, for the first time in any pleading, a violation of the consent
agreement on the north parcel of the property. (R. 116-26). The
allegations in the amended complaint concerned the restaurant
allegedly exceeding the scope of use permitted by the consent
agreement. Id.
In early 2019, the restaurant ceased operations in the park. (R.
769). It revoked the license agreement with the City. (R. 769, 1172-
73).
Later in 2019, 1000 Brickell moved for leave to file the second
amended complaint (the operative complaint) . (R. 411-16) . It alleged,
like it did in the first amended complaint, a violation of the consent
agreement on the north parcel of the property only. (R. 1794-1807).
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The allegations concerned the restaurant allegedly exceeding the
scope of use permitted by the consent agreement. Id.
The operative complaint alleged four counts: (1) quiet title; (2)
declaratory judgment; (3) breach of the warranty deed; and (4) breach
of the consent agreement. (R. 1802-07). The latter two counts sought
damages based on the City collecting rent from the restaurant. (R.
1805-07). Eventually, the trial court granted 1000 Brickell's motion
for leave to amend. (R. 1793).
The City filed an answer and affirmative defenses to the
operative complaint. (R. 1852-59). Among other affirmative defenses,
the City raised section 95.36(1), Florida Statutes, the five-year
statute of limitations in section 95.11(2) (b), Florida Statutes, and
waiver. (R. 1857-58).
The parties filed competing motions for summary judgment
under the then -governing summary judgment standard (the old
standard). (R. 272-372, 1865-85). 1000 Brickell's motion sought
summary judgment on the counts for quiet title and declaratory
judgment. (R. 272-96). It never moved for summary judgment on the
counts for damages, whether in whole or in part.
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The City's motion sought final summary judgment on all counts
based on section 95.36(1) or the five-year statute of limitations in
section 95.11(2)(b). (R. 1865-75). As to the damages counts
specifically, the City moved for summary judgment on an alternative
ground: sovereign immunity. (R. 1874-78).
Both parties filed a response in opposition to the other party's
motion. (R. 718-1219, 1886-1992). And both parties filed a reply in
support of their respective motions. (R. 1250-1463, 1999-2012).
In the "statement of undisputed facts” section of 1000 Brickell's
motion for summary judgment, 1000 Brickell claimed it did not
become aware of the restaurant's expanded operations until less than
two years before it filed suit. (R. 279). The City, however, presented
evidence showing 1000 Brickell knew, for seven years or more before
it filed suit, of the restaurant's expanded operations. (R. 893-94).
The trial court held hearings on both motions for summary
judgment separately, beginning with 1000 Brickell's motion. (R.
2084-2130). After the hearing on the City's motion, (R. 2142-75), the
court entered an order on the competing motions, in which it granted
the City's motion for summary judgment on the damages counts (III
and IV) based on sovereign immunity. (R. 2030, 2034). But the court
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otherwise denied the City's motion and granted 1000 Brickell's
motion for summary judgment. (R. 2029-36). The court then entered
final judgment for 1000 Brickell. (R. 2037-39). However, the City
successfully moved for rehearing: the court granted rehearing,
vacated the final judgment for 1000 Brickell, and entered final
summary judgment for the City. (R. 2041-49, 2177, 2180-81). The
court based its final judgment for the City on section 95.36(1) only.
(R. 2180).
In Case No 3D20-1046, 1000 Brickell appealed the final
judgment for the City. In the Initial Brief, it argued section 95.36(1)
did not apply. (R. 2303-49). 1000 Brickell also specifically requested
final judgment in its favor. (R. 2349).1
In the Answer Brief, the City argued in favor of the application
of section 95.36(1). The City also offered alternative reasons to affirm,
including the statute of limitations. In addition, the City argued
against 1000 Brickell obtaining final judgment on remand.
1 To the extent it is necessary to do so, the Court can take judicial
notice of the briefs filed in Case No. 3D20-1046. See Hunt v. State,
613 So. 2d 893, 898 n.5 (Fla. 1992) (taking judicial notice of the
record in another court); Delivorias v. Delivorias, 80 So. 3d 352, 354
(Fla. 1st DCA 2011) (same).
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In the Reply Brief, 1000 Brickell again contended against the
application of section 95.36(1). It also disputed the application of the
statute of limitations. However, 1000 Brickell never disputed the
application of sovereign immunity over Counts III and IV (the
damages counts) . In conclusion, 1000 Brickell sought final judgment
in its favor or further proceedings.
This Court ultimately reversed the final judgment for the City
on Counts I and II, while affirming summary judgment for the City
on Counts III and IV. See 1000 Brickell, Ltd. v. City of Miami, 339 So.
3d 1091 (Fla. 3d DCA 2022). This Court held that section 95.36(1)
did not apply. It did not discuss other issues, such as the statute of
limitations and waiver. In conclusion, this Court remanded for
further proceedings. Id. at 1096-97.
On remand, 1000 Brickell moved to vacate the final judgment
entered in the City's favor and reinstate the final judgment in its
favor. (R. 2250-52). The City opposed the motion to reinstate and filed
a renewed motion for final summary judgment under the new
summary judgment standard. (R. 2297-2300, 2371-80). The motion
asserted the five-year statute of limitation barred the remaining
counts. (R. 2371-80).
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First, the trial court held a hearing on 1000 Brickell's motion to
vacate and reinstate. (S.R. 142-53). After listening to arguments of
counsel, the court agreed to vacate the final judgment for the City as
to Counts I and II only (consistent with this Court's opinion), but
denied the motion to reinstate the final judgment for 1000 Brickell.
(S.R. 151-52). The court agreed to hear the City's renewed motion for
summary judgment. Id. It entered a written order reflecting the same.
(R. 2934).2
Following a hearing on the City's renewed motion for final
summary judgment, (S.R. 163-87), the trial court denied the motion.
(R. 3215-19). In doing so, the court reasoned the statute of
limitations did not bar the causes of action because the continuing
breach doctrine applied, and the operative complaint related back to
the original complaint. (R. 3218-19). The court then entered final
judgment for 1000 Brickell. (R. 3211-13). The City timely appealed.
2 Before the City filed its renewed motion for final summary
judgment, the trial court stated it would not consider such a motion.
(S.R. 130-35). This led the City to file a petition for writ of mandamus
in Case No. 3D22-1347, which this Court denied. However, after the
City filed its motion, the trial court agreed to hear the motion.
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STANDARD OF REVIEW
This appeal requires the Court to review, under the new
summary judgment standard, the denial of summary judgment for
one party and the granting of summary judgment for the other.
Summary judgment is appropriate where "there is no genuine
dispute as to any material fact and the movant is entitled to judgment
as a matter of law." Fla. R. Civ. P. 1.510(a) (2022). "In determining
whether a genuine dispute of material fact exists, the court must view
the evidence and draw all factual inferences therefrom in a light most
favorable to the non-moving party and must resolve any reasonable
doubts in that party's favor." Brevard Cnty. v. Waters Mark Dev.
Enterprises, LC, 350 So. 3d 395, 398 (Fla. 5th DCA 2022) (applying
the new summary judgment standard). Ultimately, a trial court's
ruling on a motion for summary judgment is reviewed de novo.
Simmons v. Pub. Health Tr. of Miami -Dade Cnty., 338 So. 3d 1057,
1060 (Fla. 3d DCA 2022); Brevard Cnty., 350 So. 3d at 399. This
means "the appellate court uses the trial court's record but reviews
the evidence and law without deference to the trial court's rulings."
Appeal, Black's Law Dictionary (11 th ed. 2019) .
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SUMMARY OF THE ARGUMENT
The trial court erred in entering final summary judgment for
1000 Brickell. The parties filed competing motions for summary
judgment. Both motions raised the question of whether, under the
consent agreement, the restaurant's expanded operations in the park
entitled 1000 Brickell to possession of the entire property. The City
maintains it is entitled to summary judgment based on the statute of
limitations or, at the very least, genuine disputes of material fact
preclude summary judgment for 1000 Brickell.
For purposes of analyzing the City's motion for summary
judgment, the outcome turns on whether the five-year statute of
limitations began to run once the causes of action could be brought
or whether 1000 Brickell could file suit whenever it wanted, for as
long as the restaurant operated in the park. The former is true. The
statute of limitations begins to run once the cause of action may be
brought. Plaintiffs cannot sit on their hands and file suit more than
five years later. Otherwise, courts are treating the statute of
limitations as merely a suggestion from the Legislature and not a
command from it. This is entirely improper. As a result, final
summary judgment in the City's favor is required.
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At the very least, 1000 Brickell is not entitled to final summary
judgment. For purposes of analyzing 1000 Brickell's motion for
summary judgment, the case reflects two competing narratives. On
the one hand, 1000 Brickell framed the case as one where, until
shortly before it filed suit, it had no clue of the restaurant's expanded
operations. On the other hand, the City presented evidence showing
1000 Brickell knew, for nearly seven years or more before it filed suit,
of the restaurant's expanded operations. These competing versions
of events precluded final summary judgment for 1000 Brickell.
Indeed, the record demonstrated genuine disputes as to material
facts, or no entitlement to judgment as a matter of law, on the issues
of forfeiture, the statute of limitations, and waiver. Thus, if the City
is not entitled to final summary judgment, neither is 1000 Brickell.
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ARGUMENT
I. THE TRIAL COURT ERRED IN DENYING THE CITY'S
MOTION FOR FINAL SUMMARY JUDGMENT BECAUSE
THE FIVE-YEAR STATUTE OF LIMITATIONS BARS 1000
BRICKELL'S CAUSES OF ACTION.
The first issue presented is whether the trial court erred in
denying the City's renewed motion for final summary judgment on
the statute of limitations. The parties agreed the applicable statute of
limitations is five years. See § 95.11(2)(b), Fla. Stat. (providing for a
five-year statute of limitations for "[a] legal or equitable action on a
contract, obligation, or liability founded on a written instrument").
With the applicable statute of limitations established, the question
then becomes: When did the causes of action accrue?
"A cause of action accrues when the last element constituting
the cause of action occurs." § 95.031(1), Fla. Stat. "Put another way,
the limitations period begins to run when the action 'may be
brought."' City of Riviera Beach v. Reed, 987 So. 2d 168, 170 (Fla.
4th DCA 2008) (quoting State Farm Mut. Auto. Ins. Co. v. Lee, 678
So. 2d 818, 821 (Fla. 1996)). In the context of cases subject to section
95.11(2) (b), the cause of action accrues on the date of the breach, not
the date the breach is discovered. See Fed. Ins. Co. v. Sw. Florida
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Ret. Ctr., Inc., 707 So. 2d 1119, 1122 (Fla. 1998); Lee, 678 So. 2d at
820; Med. Jet, S.A. v. Signature Flight Support -Palm Beach, Inc., 941
So. 2d 576, 578 (Fla. 4th DCA 2006). As explained below, 1000
Brickell's causes of action accrued more than five years before it filed
the original complaint or more than five years before it filed the
operative complaint which did not relate back to the original.
A. 1000 Brickell filed the original complaint more than
- five years after its causes of action accrued:
1000 Brickell filed its original complaint in 2014. (R. 31) . In the
prior appeal on the issue of section 95.36, Florida Statutes (1974), it
argued to this Court that "the City's fee simple determinable estate
in the Park Property was automatically terminated, and title thereto
reverted to [1000 Brickell]," in "early 2000." (R. 2829, 2851). 1000
Brickell should not be permitted to backtrack from this stipulation.
See Delgado v. Agency for Health Care Admin., 237 So. 3d 432, 437
(Fla. 1st DCA 2018) ("It is the policy of the law to encourage and
uphold stipulations in order to minimize litigation and expedite the
resolution of disputes." (quoting Spitzer v. Bartlett Bros. Roofing, 437
So. 2d 758, 760 (Fla. 1st DCA 1983))); see also Blumberg v. USAA
Cas. Ins. Co., 790 So. 2d 1061, 1066 (Fla. 2001) ("A claim made or
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position taken in a former action or judicial proceeding will, in
general, estop the party to make an inconsistent claim or to take a
conflicting position in a subsequent action or judicial proceeding to
the prejudice of the adverse party.").
Under 1000 Brickell's theory of the case, it could have filed suit
against the City and sought reversion approximately fourteen years
before it filed suit. 1000 Brickell's arguments essentially concede the
point that the lawsuit was filed more than five years after the causes
of action accrued. See § 95.031(1), Fla. Stat. ("A cause of action
accrues when the last element constituting the cause of action
occurs."); see also Reed, 987 So. 2d at 170 ("[T]he limitations period
begins to run when the action 'may be brought."' (quoting Lee, 678
So. 2d at 821)). On this simple basis alone, the trial court erred in
denying the City's motion for final summary judgment.
Even if 1000 Brickell's stipulation is not reason enough to
reverse, other facts establish why its causes of action accrued more
than five years before it filed suit. In 2007, the restaurant made
substantial changes to the property. (R. 2492-95). 1000 Brickell
believed these actions violated the consent agreement. Those actions
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occurred more than five years before 1000 Brickell filed the original
complaint.
For one or all these reasons, 1000 Brickell filed the original
complaint outside the five-year statute of limitations. The trial court
erred in determining otherwise.
B. The continuing breach doctrine does not apply.
To overcome all the stipulations and facts establishing 1000
Brickell's failure to file the original complaint within the statute of
limitations, the trial court relied on the continuing breach doctrine.
This doctrine cannot apply here.
The continuing breach doctrine (otherwise known as the
continuing violation doctrine) is a doctrine borrowed from the tort
context. Winn -Dixie Stores, Inc. v. Dolgencorp, LLC, 746 F.3d 1008,
1042 (11th Cir. 2014). The doctrine "distinguishes between a single
act that causes multiple, cascading harms, and recurrent, repetitive
acts excepted from the running of the statute of limitations[.]" Id.
Florida courts have been reluctant to expand the continuing
breach doctrine to a restrictive covenant running with the land. See
id. at 1043 ("No Florida authority has addressed whether the
continuing violation doctrine applies to restrictive covenants running
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with the land."). And this Court has been reluctant to expand the
continuing tort doctrine even within the context of torts. See Aristide
v. Jackson Mem'l Hosp., 917 So. 2d 253, 255 (Fla. 3d DCA 2005).
("The doctrine of continuing tort is also inapplicable. No Florida
appellate court has applied the continuing tort doctrine to medical
malpractice cases."). This case involves something other than a tort
or a mere restrictive covenant: a reverter provision.3
This Court should not expand the continuing breach doctrine
to reverter provisions in warranty deeds. The legal effect of triggering
a reverter provision demonstrates why.
Once triggered, a reverter provision nullifies the warranty deed,
including its conditions, and the parties return to the legal positions
they had with respect to the property before they executed the deed.
See Jacksonville Transp. Auth. v. Cont'l Equities, Inc., 636 So. 2d
1354, 1357 (Fla. 1st DCA 1994) ("When the interests conveyed by the
deed reverted to the grantors . . ., the quitclaim deed, including its
3 Remarkably, the trial court relied on Viera v. City of Lake Worth,
Florida, 230 So. 3d 484 (Fla. 4th DCA 2017), as a Florida case
applying the continuing breach doctrine to a restrictive covenant
running with the land. (R. 3218). But Viera had nothing to do with
such a scenario. Instead, the case involved the failure to pay health
insurance benefits.
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conditions, was nullified and the parties returned to the positions
they held with respect to the property before the deed was executed.
Under these circumstances, there were no longer any obligations
between [the grantee] and the grantors relating to the quitclaim deed,
and therefore no basis for a breach of contract suit by either of the
grantors against [the grantee]."). As a result, there are no longer any
obligations between the parties. Id. In fact, the agreement is no longer
in effect. Id. This explains why the continuing breach doctrine is not
applicable in the context of reverter provisions.
Even if this Court believed the continuing breach doctrine may
apply to cases involving reverter provisions in warranty deeds, it
should not apply the doctrine here. Several circumstances, whether
viewed individually or collectively, demonstrate why.
First, the plain language of the reverter provision bars the
application of the continuing breach doctrine. It provided that if "any"
part of the property was "used for any purpose other than public park
purposes," the estate would "automatically and immediately
terminate, and all right, title and interest in and to such property
shall thereupon revert to the grantor." (R. 2383-84). Therefore, there
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could be no continuing breach, only one breach that immediately
entitled 1000 Brickell to the property.
To decide otherwise would require the Court to rewrite the
reverter provision (i.e., the contract). The Court lacks the authority
to do so. See Pol v. Pol, 705 So. 2d 51, 53 (Fla. 3d DCA 1997) ("It is
well established that a court cannot rewrite the clear and
unambiguous terms of a voluntary contract."); Walgreen Co. v.
Habitat Dev. Corp., 655 So. 2d 164, 165 (Fla. 3d DCA 1995) ("When
a contract is clear and unambiguous, the court is not at liberty to
give the contract any meaning beyond that expressed. Further, when
the language is clear and unambiguous, it must be construed to
mean just what the language therein implies and nothing more."
(citations and quotation marks omitted)); Universal Med. Inv. Corp.
v. Mike Rollison Fence, LLC, 331 So. 3d 242, 247 (Fla. 1st DCA 2021)
("A party is bound by, and a court is, powerless to rewrite, the clear
and unambiguous terms of a voluntary contract." (citation omitted)).
This is reason enough to reject the continuing breach doctrine here.
Second, even in jurisdictions where the continuing violation
doctrine applies, courts recognize the doctrine does not apply to
violations based on fixed structures. See Winn -Dixie, 746 F.3d at
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1043-44 (recognizing fixed structure cases are not subject to the
continuing violation doctrine); Russell v. Williams, 964 P.2d 231
(Okla. Civ. App. 1998) (refusing to apply the continuing violation
doctrine to a case involving a fixture, a "modular home," violating a
restrictive covenant prohibiting buildings near property lines). Here,
any violation of the warranty deed or consent agreement is
necessarily based on a fixed structure (the restaurant). This renders
the continuing violation doctrine inapplicable here.
Despite the plain language of the reverter provision and the
nature of the alleged violation, the trial court relied on five cases for
the proposition that the continuing breach doctrine should apply:
Grove Isle Ass'n, Inc. v. Grove Isle Associates, LLLP, 137 So. 3d 1081,
1094-95 (Fla. 3d DCA 2014) (excessive fees and dues); City of Quincy
v. Womack, 60 So. 3d 1076, 1077-78 (Fla. 1st DCA 2011) (failure to
repair a dam and spillway); Winn -Dixie, 746 F.3d at 1043-44
(violations of grocery exclusives in leases with shopping centers);
Viera v. City of Lake Worth, Florida, 230 So. 3d 484, 485-87 (Fla. 4th
DCA 2017) (failure to make periodic payments of health insurance
benefits); XP Glob., Inc. v. AVM, L.P., 16-CV-80905, 2016 WL
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4987618, at *3-4 (S.D. Fla. Sept. 19, 2016) (continued use of
confidential information). None of these cases help 1000 Bricke11.4
In contrast with. the opinions cited by the trial court, this case
involves a reverter provision which, if triggered, automatically entitles
1000 Brickell to the property. No agreement between the parties,
whether the warranty deed or consent agreement, entitles 1000
Brickell to periodic payments or otherwise entitles 1000 Brickell to
damages. And nothing in the reverter provision resembles the
contract provisions at issue in the opinions cited by the trial court.
Ultimately, the plain language of the reverter provision, rather
than a judicial doctrine, should control how to interpret a breach of
the provision. See Pot, 705 So. 2d at 53; Walgreen, 655 So. 2d at 165;
Universal Med. Inv., 331 So. 3d at 247 ("A party is bound by, and a
court is powerless to rewrite, the clear and unambiguous terms of a
voluntary contract." (citation omitted)). The plain language of the
4 In Grove Isle, this Court applied the continuing breach doctrine to
a breach of contract count, but not the counts implicating a
restrictive covenant. 137 So. 3d at 1086-95. Apparently, the Eleventh
Circuit's observation about Florida law remains sound: No Florida
authority has applied the continuing breach doctrine to restrictive
covenants running with the land. Winn -Dixie, 746 F.3d at 1043.
Certainly, the trial court did not cite any case to the contrary.
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reverter provision here could not be any clearer in refuting the notion
of a continuing breach.
Although the trial court believed collecting rent from the
restaurant mandated the application of the continuing breach
doctrine, (R. 3219), neither the warranty deed nor consent agreement
prohibited collecting rent. Moreover, the only remaining counts
(Counts I and II) do not seek damages for rent payments. Thus, any
breaches of those counts do not concern payments owed. Instead,
the alleged breach here involved a fixed structure (the restaurant)
expanding its footprint. This circumstance brings this case, even
under one of the key opinions cited by the trial court (Winn -Dixie),
outside the ambit of cases applying the continuing breach doctrine.
Besides relying on easily distinguishable cases, the trial court
misunderstood the City's argument on the legal effect of triggering a
reverter provision. As explained above, once a party triggers a reverter
provision, the warranty deed is nullified, and the parties return to
the positions they had with respect to the property before they
executed the deed. See Jacksonville Transp. Auth., 636 So. 2d at
1357. In rejecting this argument, the trial court reasoned that 1000
Brickell did not actually possess the property upon the alleged
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breach. (R. 3219). But the City did not suggest 1000 Brickell actually
possessed the property. The City meant the legal effect of triggering
a reverter provision returns the parties to the legal positions they had
with respect to the property before they executed the deed. Put
another way, a breach of a reverter provision transfers legal
ownership of the property back to the grantor (or its heirs or assigns) .
As a result of this automatic and immediate change, one breach can
occur and no other. It is then incumbent on the grantor (or its heirs
or assigns) to file a lawsuit seeking reversion within the statute of
limitations. But 1000 Brickell failed to do so. Final summary
judgment in the City's favor is, therefore, required.
C. Even if 1000 Brickell filed the original complaint
within the statute of limitations, it filed the operative
complaint, which does not relate back to the original
complaint, outside the statute of limitations.
If this Court agrees with the City on the inapplicably of the
continuing breach doctrine, and yet somehow concludes 1000
Brickell filed its original complaint within the statute of limitations,
1000 Brickell's causes of action are still time barred. This is so
because the amended complaints, which first raised the issue of the
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restaurant allegedly violating the consent agreement, did not relate
back to the original complaint.
Although pleading rules are to be liberally construed, this
liberality has its limits. Castro v. Linfante, 307 So. 3d 110, 113 (Fla.
3d DCA 2020). One such limit is the well -established principle that
"[o]ne cannot defeat the bar of the statute of limitations by filing a
new cause of action labelled as an amended complaint." Id. (quoting
Sch. Bd. of Broward Cty. v. Surette, 394 So. 2d 147, 154 (Fla. 4th
DCA 1981)). This principle is known as the relation back doctrine.
Rule 1.190 governs amended pleadings. It provides:
When the claim or defense asserted in the amended
pleading arose out of the conduct, transaction, or
occurrence set forth or attempted to be set forth in the
original pleading, the amendment shall relate back to a the
date of the original pleading.
Fla. R. Civ. P. 1.190(c). In other words, rule 1.190(c) "allow[s] relation
back where the claims from the amended pleading arise out of the
same conduct, transaction, or occurrence as in the original, timely
filed complaint." Kopel v. Kopel, 229 So. 3d 812, 816 (Fla. 2017)
(emphasis added). See also Palm Beach Cnty. Sch. Bd. v. Doe, 210
So. 3d 41, 47 (Fla. 2017) ("The proper focus of the inquiry is not
whether the amended pleading sets forth a new or different claim,
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but whether the claims within the amended pleading are part of the
same conduct, transaction, or occurrence as in the original
pleading.") (emphasis added) . Ultimately, the original complaint must
give the defendant "fair notice" of the general factual scenario or
factual underpinning of the claim. Kopel, 229 So. 3d at 816.
In this case, the operative complaint (like the first amended
complaint) did not relate back to the filing of the original complaint
because the operative complaint was not based on the same conduct,
transaction, or occurrence as in the original complaint. The original
complaint did not offer "fair notice" of the later claims made in the
operative complaint. The factual underpinnings of both complaints
demonstrate why.
The warranty deed conveyed two parcels of a property to the
City: a north parcel and a south parcel. (R. 2383-84). Its reverter
clause provided that if "any" part of the property was "used for any
purpose other than public park purposes," the entire property would
revert to the grantor. Id. Years later, the City and 1000 Brickell
entered into a consent agreement which permitted the restaurant to
use a portion of the north parcel of the property for its restaurant.
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(R. 2386-87). The consent agreement had nothing to do with the
south parcel of the property. Id.
In the original complaint, 1000 Brickell alleged a violation of the
warranty deed on the south parcel of the property only. (R. 31-40).
That complaint sought to enjoin the City from conveying the south
parcel to a private entity (Brickell Flatiron, LLC). (R. 36). The original
complaint had nothing to do with the north parcel of the property,
the consent agreement, or the restaurant on the north parcel of the
property (or any other restaurant). (R. 31-40).
In the operative complaint (like the first amended complaint),
1000 Brickell alleged a violation of the warranty deed and consent
agreement on the north parcel of the property only. (R. 1794-1851).
The allegations concerned the restaurant exceeding the scope of use
permitted by the consent agreement. Id.
As these circumstances demonstrate, the operative complaint
alleged new conduct and occurrences that were not included in the
original complaint and had nothing to do with the parcel of property
at issue in the original complaint. For example, all the information
regarding the restaurant, which did not operate on the south parcel
of the property and is in no way mentioned in the original complaint.
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The operative complaint not only alleged new conduct and
occurrences, but it also alleged a new transaction (the consent
agreement). The complaint hinged on an alleged violation of that
agreement. Indeed, as framed by 1000 Brickell's allegations, the City
did not trigger the reverter provision until it allowed the restaurant
to exceed the scope of use permitted by the consent agreement. In
other words, the consent agreement superseded the warranty deed;
it became the governing transaction. Given all these circumstances,
it cannot be said that the operative complaint related back to the
original complaint. See Floyd v. State (In re Forfeiture of: £1992
Pontiac Firebird No. 1G2FS23T3NL212004), 47 So. 3d 344 (Fla. 2d
DCA 2010) (holding the relation back doctrine did not apply, even
though the amended complaint involved the same parties and cause
of action (i.e., forfeiture)).
As the operative complaint did not relate back to the original
complaint, 1000 Brickell's causes of action are time barred even if
1000 Brickell filed the original complaint within the five-year statute
of limitations. As explained above, the restaurant made substantial
changes to the property in 2007. (R. 2492-95). By 2009, the
restaurant finished construction on a new structure. (R. 2532). 1000
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Brickell argued that such actions violated the consent agreement.
These actions occurred more than five years before 1000 Brickell filed
the operative complaint (and the first amended complaint).
Moreover, 1000 Brickell essentially conceded that its causes of
action accrued no later than 2012. (R. 1798) (alleging 1000 Brickell
became aware of a violation of the warranty deed and consent
agreement loin or about October 22, 2012"); (R. 294) (referring to the
date of discovery as "the latest" date when its causes of action could
accrue). Although, as noted before, the date of breach and not the
date of discovery triggers the running of the statute of limitations, see
Fed. Ins. Co., 707 So. 2d at 1122; Lee, 678 So. 2d at 820; Med. Jet,
S.A., 941 So. 2d at 578, logic dictates the date of discovery is the
latest time when the breach could have occurred. But, even giving
1000 Brickell the benefit of the date of discovery, it failed to file the
operative complaint within five years of that date. Put simply, the
filing of the original complaint within the five-year statute of
limitations would not save 1000 Brickell's case because the operative
complaint did not relate back to it.
Despites all these circumstances, the trial court reasoned that
the relation back doctrine applied because the allegations in each
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complaint "relate to the same transaction —the Warranty Deed." (R.
3219) (emphasis added). But the allegations in each complaint do not
relate to the same transaction. The allegations in the operative
complaint relate to a new transaction —the consent agreement.
For one or all these reasons, the trial court erred in denying the
City's renewed motion for final summary judgment. This Court
should reverse and remand for entry of judgment in the City's favor.
II. THE TRIAL COURT ERRED IN GRANTING 1000
BRICKELL'S MOTION FOR FINAL SUMMARY JUDGMENT
BECAUSE GENIUNE DISPUTES AS TO MATERIAL FACTS
EXIST OR 1000 BRICKELL IS NOT ENTITLED TO
JUDGMENT AS A MATTER OF LAW.
The second question presented is whether, even if the City is
not entitled to summary judgment, is 1000 Brickell entitled to such?
For purposes of analyzing 1000 Brickell's motion for summary
judgment, the City is the non-moving party. This means the Court
"must view the evidence and draw all factual inferences therefrom in
a light most favorable" to the City and "must resolve any reasonable
doubts" in the City's favor. Brevard Cnty. v. Waters Mark Dev.
Enterprises, LC, 350 So. 3d 395, 398 (Fla. 5th DCA 2022) (applying
the new summary judgment standard). And it is important to
remember that "a motion for summary judgment is not a trial by
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affidavit or deposition. Summary judgment is not intended to weigh
and resolve genuine issues of material fact, but only identify whether
such issues exist. If there is disputed evidence on a material issue of
fact, summary judgment must be denied and the issue submitted to
the trier of fact." Shands v. City of Marathon, 261 So. 3d 750, 753
(Fla. 3d DCA 2019) (quoting Perez-Gurri Corp. v. McLeod, 238 So. 3d
347, 350 (Fla. 3d DCA 2017)).
With these well -established principles in mind, this Court must
analyze the competing narratives offered by the parties. On the one
hand, 1000 Brickell framed the case as one where, until shortly
before it filed suit, it had no clue of the restaurant's expanded
operations. (R. 279). On the other hand, the City presented evidence
showing 1000 Brickell knew, for nearly seven years or more before it
filed suit, of the restaurant's expanded operations. (R. 893-94). The
City even provided evidence showing that 1000 Brickell's managing
partner expressly approved of the expanded operations. (R. 894). This
evidence contradicted the so-called "undisputed fact" of when 1000
Brickell discovered the expanded operations. As explained below, the
competing narratives and governing law precluded summary
judgment for 1000 Brickell.
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A. 1000 Brickell is not entitled to summary judgment on
the issue of forfeiture.
In first place, 1000 Brickell is not entitled to judgment, as a
matter of law, on the issue of reversion (i.e., forfeiture against the
City). "[I]t is well settled that `equity abhors a forfeiture,' that 'such
restrictions are not favored in law if they have the effect of destroying
an estate,' and that they 'will be construed strictly and will be most
strongly construed against the grantor."' White v. Metro. Dade Cty.,
563 So. 2d 117, 125 (Fla. 3d DCA 1990) (quoting Dade Cty. v. City of
N. Miami Beach, 69 So. 2d 780, 782-83 (Fla. 1953)). See also Torres
v. K-Site 500 Assocs., 632 So. 2d 110, 112 (Fla. 3d DCA 1994) ("It is
a fundamental principle that equity prefers not to enforce the breach
of contractual provisions which result in extreme forfeiture."); Tiffany
Realty, Inc. v. Alvin, 311 So. 2d 832, 834 (Fla. 3d DCA 1975) ("It is a
well settled principle of Florida law that equity abhors a forfeiture.").
"This is all the more true when the forfeiture is against the public."
Dade Ctv., 69 So. 2d at 783.
Here, 1000 Brickell demanded forfeiture against the City based
on the City allegedly violating the consent agreement. The argument
is premised on the notion that any expansion of the restaurant in the
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north parcel of the property automatically changed the nature of the
entire property (north and south parcel) into something other than a
public park. This premise is wrong. As the premise is wrong, so is the
conclusion that followed.
A restaurant operated for a commercial benefit is not
necessarily inconsistent with "public park" purposes. See White, 563
So. 2d at 124 ("Appellant/heirs next argue that turning the tennis
complex over to a commercial operator violates the deed restriction.
We do not agree. Florida courts have consistently ruled that
commercial benefit does not defeat a park purpose."); Antioch Univ.
v. State, Dep't of Nat. Res., 647 So. 2d 915 (Fla. 4th DCA 1994)
(affirming a jury verdict finding the "[u]se or structures of the Garden
Club or refreshment building" did not violate a reverter provision that
required the land to be "used and devoted solely and exclusively for
State Park purposes"). This conclusion is mandated by the Florida
Supreme Court's adoption of the "modern concept" of public parks —
one which recognizes the value of restaurants in parks and approves
the presence of a private corporation that may profit from its activities
there. The Supreme Court elaborated on the modern concept of
public parks as follows:
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This definition explains the change in concept of a park
from the time when a park was understood to be an open
square or plaza, usually containing shade trees and seats,
to the present, when a park is considered not only as
ornamental but also as a place for recreation and
amusement. Changes in the concepts of parks have
continued and the trend is certainly toward expanding and
enlarging the facilities for amusement and recreation
found therein.
The fact that charges will be made for use of the facilities
and that a private corporation will profit therefrom are not
controlling.
Hanna v. Sunrise Recreation, Inc., 94 So. 2d 597, 600-01 (Fla. 1957).
In essence, 1000 Brickell urged the trial court to apply the
ancient concept of a park —trees, grass, and other vegetation without
any commercial activity. But that ancient concept conflicts with the
Florida Supreme Court's adoption of the modern concept. Id. at 601.
Thus, 1000 Brickell failed to establish that it was entitled to
judgment as a matter of law on the question of whether a restaurant's
use of only a portion of one parcel of the property required forfeiture.
This is especially true given the evidence of 1000 Brickell's express
or implied approval of the restaurant's expanded operations.
Given all the facts of this case, a trier of fact should consider
the issue of forfeiture. And any doubt on this point must be resolved
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in the City's favor given the well -established law that equity abhors a
forfeiture, especially against the public. See Dade Cty., 69 So. 2d at
782-83; Torres, 632 So. 2d at 112; White, 563 So. 2d at 125; Tiffany
Realty, 311 So. 2d at 834.
B. If the City is not entitled to summary judgment on the
issue of the statute of limitations, 1000 Brickell is not
entitled to summary judgment on the issue.
Even if this Court believed forfeiture was required as a matter
of law, the City presented affirmative defenses, with supporting
evidence, establishing why final summary judgment for 1000 Brickell
was inappropriate. This included the statute of limitations defense.
In the interest of brevity, the City adopts and incorporates the legal
analysis and arguments on this defense raised above, with additional
points addressed below.
When moving for summary judgment, 1000 Brickell argued that
its causes of action accrued on the date it allegedly discovered the
breach (October 2012). (R. 294). It even referred to this date of
discovery as undisputed. (R. 279) (listing the date in the "statement
of undisputed facts") . 1000 Brickell also referred to the date of
discovery as "the latest" date when its causes of action could accrue,
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thereby undermining its later claim on the continuing breach
doctrine. (R. 294).
As explained above, the date of breach, not the date of discovery
controls. See Fed. Ins. Co., 707 So. 2d at 1122; Lee, 678 So. 2d at
820; Med. Jet, S.A., 941 So. 2d at 578. However, if the City is in any
way mistaken on this point, the City presented showing that 1000
Brickell knew of the restaurant's expanded operations and expressly
approved of them. (R. 893-94). This obviously created a genuine
dispute of facts.
Furthermore, as discussed before, the City presented evidence
showing the restaurant expanded operations in 2007 (seven years or
more before 1000 Brickell filed suit) and finished construction on a
new structure no later (although likely much earlier) than 2009. (R.
2492-95, 2532). And 1000 Brickell previously stipulated that it could
have filed suit in 2000. (R. 2829, 2851). At the very least, these facts,
whether viewed individually or collectively, created genuine disputes
on the date the causes of action accrued.
Finally, even if this Court believed the continuing. breach
doctrine could apply, the evidence submitted by the City established,
at the very least, a genuine dispute of material facts or no entitled to
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judgment as a matter of law. The continuing breach doctrine is
usually a question of fact for the trier of fact (unless for reasons
analyzed above, the doctrine is inapplicable to a cause of action) . See
Pearson v. Ford Motor Co., 694 So. 2d 61, 67-68 (Fla. 1st DCA 1997)
("Whether the continuing torts doctrine applies to the facts of a case
is for a trier of fact to decide."). For one or all these reasons, the
statute of limitations precluded summary judgment for 1000
Brickell.
C. 1000 Brickell is not entitled to summary judgment on
the -issue of -waiver.
Another affirmative defense also precluded summary judgment
for 1000 Brickell: the issue of waiver. "A waiver is the intentional
relinquishment of a known right and may be express or implied."
Torres, 632 So. 2d at 112. Generally, the issue of waiver is one for
the fact finder. Popular Bank of Florida v. R.C. Asesores Financieros,
C.A., 797 So. 2d 614, 619 (Fla. 3d DCA 2001).
1000 Brickell argued the restaurant exceeded the portion of the
park allowed for restaurant purposes and this triggered the reverter
provision. This means, as analyzed before, 1000 Brickell's lawsuit is
premised on the notion that restaurant purposes are not park
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purposes. Even assuming for the sake of argument this premise is
correct, then the consent agreement nullified the reverter provision.
The warranty deed prohibited the use of "any" portion of the
property for "any purpose other than public park purposes ...." (R.
1808-09). But the consent agreement authorized the use of a portion
of the property for restaurant purposes. (R. 1810-11) . If restaurant
purposes are never park purposes, as 1000 Brickell essentially
contends, the consent agreement cannot be reconciled with the
warranty deed. After all, the deed prohibited the use of any portion
of the property for anything other than public park purposes.
Moreover, the consent agreement did not provide that, in the
event the restaurant exceeded the scope of use, the entire property
would automatically revert to 1000 Brickell. (R. 1810-11). The
consent agreement should have included such express language if it
wanted the reverter provision to survive. Merely noting the reverter
provision was insufficient. Any doubt on this point must be resolved
in the City's favor given all the authority cited above regarding how
equity abhors a forfeiture. Put another way, to the extent there is any
ambiguity, the Court must construe the consent agreement to avoid
forfeiture. See Roschman Partners v. S.K. Partners I, Ltd., 627 So. 2d
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2, 7 n.7 (Fla. 4th DCA 1993) ("[A]n ambiguous provision should be
construed where possible to avoid a forfeiture.").
In addition, 1000 Brickell waived the reverter provision "by
actions or conduct warranting an inference that a known right has
been relinquished." Torres, 632 So. 2d at 112. 1000 Brickell's
managing partner wrote a letter to the City urging a commercial use
of the north parcel of the property for the restaurant. (R. 744-45). He
also regularly visited the restaurant from the time the restaurant's
owner leased the property (1999) to the time when their companies
litigated against each other (2013). (R. 893-94). This included the
period during which the restaurant significantly expanded its
operations (in 2000 or 2007 and beyond). And 1000 Brickell's
managing partner expressly approved of the expanded operations. (R.
894). Yet, 1000 Brickell waited years (until 2013) before notifying the
City of an alleged violation of the reverter provision. (R. 1798). Its
"conduct in failing to promptly invoke" the reverter provision and "in
electing to allow" the restaurant to proceed with expanded operations
"placed [the City and the restaurant] off guard, and lulled them into
believing" that 1000 Brickell was "not intending to enforce the
perceived breach" of the reverter provision. Torres, 632 So. 2d at 112.
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For one or all these reasons, the issue of waiver precludes
summary judgment for 1000 Brickell. This is an issue for a fact finder
to resolve.
Although 1000 Brickell argued the City waived the defense of
waiver, namely, waiver by conduct, it was mistaken. The City pled
waiver as an affirmative defense multiple times. (R. 267, 1857). While
it is true the City did not use the magic words "waiver by conduct,"
neither the plain language of Florida Rule of Civil Procedure_1.110(d)
nor any case law cited by 1000 Brickell required the City to use such
magic words. And the trial court's order on 1000 Brickell's motion for
summary judgment did not find the City waived the defense of waiver.
(R. 2034, 3211-13).
Waiver, in addition to or in lieu of, all the arguments raised
above, precluded summary judgment for 1000 Brickell. The case
should be submitted to a trier of fact, assuming the City's motion for
final summary judgment did not entitle it to final judgment.
CONCLUSION
For these reasons, this Court should reverse the final judgment
entered in 1000 Brickell's favor and the order denying the City's
renewed motion for final summary judgment. On remand, the trial
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court should be instructed to enter final judgment in the City's favor.
In the alternative, this Court should reverse the judgment in 1000
Brickell's favor and remand for further proceedings, namely, a trial.
Respectfully submitted,
VICTORIA MENDEZ, City Attorney
ERIC J. EVES, Assistant City Attorney
Attorneys for Appellant
444 S.W. 2nd Avenue, Suite 945
Miami, Florida 33130-1910
Phone: (305) 416-1800
Primary Email: eeves@miamigov.com
Secondary Email: csantos@miamigov.com
By: s/ Eric J. Eves
Eric J. Eves
Florida Bar No. 91053
CERTIFICATE OF SERVICE
I certify that on March 9, 2023, the Initial Brief was emailed to
Scott D. Kravetz, Esq., at sdkravetz@duanemorris.com, and Richard
D. Shane, Esq., at rdshane@duanemorris:com.
By: s/ Eric J. Eves
39
Eric J. Eves
Florida Bar No. 91053
14278-Submittal-Eddy Leal -Initial Brief of Appellant
Submitted into the public
record for item(s) PA.1 ,
on 09/28/2023 . City Clerk
CERTIFICATE OF COMPLIANCE
I certify the Initial Brief complies with the font requirements of
Florida Rule of Appellate Procedure 9.045(b) and the word count
requirements of Florida Rule of Appellate Procedure 9.210 (a) (2) (B) .
By: s/ Eric J. Eves
40
Eric J. Eves
Florida Bar No: 91053
14278-Submittal-Eddy Leal -Initial Brief of Appellant