Associate Attorney
In Bburgert, LLC v. Benfam Holdings, LLC (Fla. 6th DCA 2026), the Sixth District Court of Appeal revisited a recurring but critical issue: whether a trial court’s failure to articulate its reasoning when granting summary judgment requires reversal. The answer, once again, is yes.
The case arose from a foreclosure action in which the trial court entered final summary judgment in favor of the plaintiff. On appeal, the defendant argued both that its affirmative defenses created genuine issues of material fact and that the trial court failed to comply with Florida Rule of Civil Procedure 1.510(a), which requires the court to “state on the record the reasons for granting or denying the motion,” either orally or in writing. The dispositive issue, however, was the trial court’s failure to explain its ruling.
Although the record included a transcript of the summary judgment hearing, the Sixth DCA found that the trial court did not articulate any specific reasons for granting summary judgment—neither during the hearing nor in its written order. That omission proved fatal. The appellate court emphasized that compliance with Rule 1.510(a) requires more than a conclusory statement that there is or is not a genuine dispute of material fact. A bare ruling granting summary judgment, without articulated reasoning, is insufficient to permit meaningful appellate review.
Because the trial court failed to comply with the rule, the Sixth DCA reversed and remanded for the limited purpose of allowing the trial court to enter an order that properly states its reasoning. Notably, the court did not even reach the appellant’s argument regarding the existence of genuine issues of material fact, as the procedural deficiency alone required reversal.
Practice pointers
- Rule 1.510(a) imposes a mandatory obligation: trial courts must clearly state their reasoning when ruling on summary judgment.
- A conclusory ruling is not enough—there must be an explanation tied to the facts and law.
- Ensure a transcript is obtained from the summary judgment hearing to preserve the issue if the court fails to comply.
- Consider seeking clarification or rehearing if the court’s reasoning is not stated on the record.
Takeaway: A summary judgment order without stated reasons is inherently vulnerable on appeal. Rule 1.510(a) is not a technicality—it is a requirement. If the trial court does not articulate its reasoning, reversal is likely, regardless of the underlying merits.
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