31 FORD LLC v. TENANT RIGHTS LLC (2026)

District Court of Appeal of Florida, Fourth District.

31 FORD LLC, Appellant, v. TENANT'S RIGHTS LLC, as assignee to Marie Zulme, Appellee.

No. 4D2026-0312

Decided: July 01, 2026

Michael Ira Bernstein, Matthew Savino and Jordan Charles Kaplan of The Bernstein Law Firm, Miami, for appellant. Daniel William Bialczak of Korte & Associates, PLLC, Palm Beach Gardens, for appellee.

31 Ford LLC (“Landlord”) appeals an order denying its motion to dismiss or transfer venue of a suit brought in Palm Beach County for return of a security deposit. We reverse based on Casa Verde MHC, LLC v. Tenant's Rights LLC, 432 So.3d 549 (Fla. 4th DCA 2026).

As in Casa Verde, the face of appellee's complaint failed to allege a basis for venue in Palm Beach County. See id. (citing Nicholas v. Ross, 721 So. 2d 1241, 1242 (Fla. 4th DCA 1998) (“[T]he plaintiff must allege in the complaint a sufficient basis for the selected venue.”)). The complaint's generalized citation to Florida Small Claims Rule 7.060 is insufficient for appellee to satisfy its burden to plead venue. See Fla. Sm. Cl. R. 7.060(a) (listing seven permissible filing locations).

Consequently, we reverse and remand with directions to grant Landlord's motion and transfer this action to Miami-Dade County court.

Reversed and remanded.

Lott, J.

Gross and Shaw, JJ., concur.

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