MARTINEZ v. BUSTAMANTE (2026)

Jhackelin Martinez and Carlos I. Bustamante entered into a premarital agreement shortly before their wedding in October 2020. Martinez filed for divorce in 2022. The parties entered a stipulated partial final judgment of dissolution of marriage in late 2024. But this partial final judgment left unresolved a provision in the premarital agreement which explains that, in the event of divorce, “[t]he marital domicile shall be occupied by Wife until her death or occupied by Husband until his death.” The court took parol evidence and ultimately declined to give the disputed provision any effect in the supplemental final judgment, finding that the provision was “ambiguous, and clearly was a mistake.” Martinez appeals, arguing that the parol evidence establishes the parties’ intention to give her a life estate in the marital domicile. For the reasons below, we affirm the supplemental final judgment.

A court generally can't resolve a “patent ambiguity” in contractual language by examining extrinsic evidence. Contragolpe LLC v. 505 NE 30 St., LLC, 403 So. 3d 358, 361 (Fla. 3d DCA 2025).¹ A patent ambiguity is readily discernible on the face of the instrument, arising from language that is “defective, obscure, or insensible.” Id. The language here is readily discernible as defective—it purports to give both parties the same right to occupy the same property. The language is also insensible. This is so because occupying a property generally means to the exclusion of others, presumably—and perhaps especially—including a newly divorced ex-spouse. The language is therefore patently ambiguous. And the patent ambiguity must be resolved, if possible, by relying on the language of the contract as a whole and canons of construction.²

Despite erroneously reviewing parol evidence, the trial court reached the correct conclusion.³ After carefully reading the contract as a whole and applying the canons of construction, we are unable to discern the relevant language's meaning without rewriting the contract and inserting terms not present. The term therefore cannot be enforced. See Bowein v. Sherman, 374 So. 3d 895, 897 (Fla. 6th DCA 2023) (declining to enforce contract where patent ambiguity exists in a material term and reaffirming principle that parol evidence cannot be taken to cure such an ambiguity); see also Shands Teaching Hosp. & Clinics, Inc. v. Mercury Ins. Co. of Fla., 97 So. 3d 204, 212 (Fla. 2012) (“[A]n appellate court should affirm a trial court that reaches the right result, but for the wrong reasons ․” (internal quotation omitted)).

Affirmed.

FOOTNOTES

1.   “However, courts allow parol evidence regarding identity, capacity, and the parties’ relationship with one another even when the ambiguity exists on the face of the document because the court would not be rewriting the terms of the contract.” Fi–Evergreen Woods, LLC v. Robinson, 135 So. 3d 331, 336 (Fla. 5th DCA 2013) (citation omitted). Those limited exceptions are not present here.

2.   We also note that the parties sought the court's assistance in interpreting the contract. No party sought reformation of the contract. Reformation has a higher standard of proof: clear and convincing evidence. See Bone & Joint Treatment Ctrs. of Am. v. HealthTronics Surgical Servs., Inc., 114 So. 3d 363, 366 (Fla. 3d DCA 2013). Additionally, as explained by our sister court:A cause of action for reformation must allege that, as a result of a mutual mistake or a unilateral mistake by one party coupled with the inequitable conduct of the other party, the contract fails to express the agreement of the parties. A mistake is mutual when the parties agree to one thing and then, due to either a scrivener's error or inadvertence, express something different in the written instrument.White v. Fort Myers Beach Fire Control Dist., 302 So. 3d 1064, 1073 (Fla. 2d DCA 2020) (citation modified).

3.   “Under the tipsy coachman rule, ‘if a trial court reaches the right result, but for the wrong reasons, it will be upheld if there is any basis which would support judgment in the record.’ ” See Ruiz v. Policlinica Metropolitana, C.A., 260 So. 3d 1081, 1090–91 (Fla. 3d DCA 2018) (citing Dade Cnty. Sch. Bd. v. Radio Station WQBA, 731 So. 2d 638, 644 (Fla. 1999)).

BOKOR, J.