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Florida Case Analysis by Alexander Rabinowitz, Esq. – July 24, 2025 Edition
In Open Range Properties v. AmeriHome Mortgage Co., the Fifth District Court of Appeal reversed a final summary judgment of foreclosure because the trial court failed to comply with the 2021 revision to Florida Rule of Civil Procedure 1.510(a).
Under the amended rule — modeled after the federal standard — trial courts are now required to state on the record the specific reasons for granting or denying summary judgment. The change was intended to improve transparency, guide appellate review, and discourage conclusory rulings.
In Open Range, however, the trial court issued a final judgment with no explanation. The transcript of the hearing also lacked any meaningful rationale — just a brief announcement that the motion was granted. The appellate court found this insufficient under the rule and reversed the judgment with instructions that the trial court must enter a revised order articulating its reasoning.
The Florida Supreme Court has been clear: trial judges must now do more than just announce a conclusion. The language of Rule 1.510(a) is mandatory, and the order (or transcript) must offer enough specificity to aid parties and appellate courts alike.
Takeaway: If you win at summary judgment, don’t let sloppy drafting steal your victory. Whether you’re the moving party or preparing the proposed order, make sure the court’s reasoning is clearly stated — either in the judgment or on the record. If it’s not, you may be celebrating a win that doesn’t survive appeal.
At Boatman Ricci, we help attorneys and trial teams frame winning orders that withstand scrutiny under Florida’s evolving procedural rules.
Have a summary judgment ruling that might be vulnerable on appeal? Contact our team before it’s too late.
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