A Florida appellate court has upheld a lower court's eviction ruling against Andrew Calhoun Saxon, affirming that his failure to pay rent resulted in a default judgment for the Bay Ranch Mobile Village. The court also ordered a minor correction to the judgment due to a scrivener's error.

The case, Saxon v. Bay Ranch Mobile Village, LLP, was decided on November 6, 2026, by the District Court of Appeal of Florida, Second District, under docket number 2D2026-1143. This decision is significant as it clarifies the legal implications of failing to deposit rent in eviction proceedings, particularly in mobile home park contexts.

Andrew Calhoun Saxon, representing himself, appealed a Judicial Default and Default Final Judgment for Possession issued by the County Court for Pinellas County. The ruling was made by Judge Susan Bedinghaus. In the lower court, Saxon was found to have not deposited his rent as required, which the court ruled constituted an absolute waiver of his defenses against eviction.

The dispute arose when Saxon failed to comply with a court order to deposit rent into the court's registry. According to Florida law, specifically section 723.063(2), failing to pay rent in this manner results in the loss of any defenses the mobile home owner may have against eviction. This law is designed to ensure that mobile home park owners can recover possession of their properties when tenants do not fulfill their rental obligations.

In the appellate ruling, the court found no error in the lower court's judgment regarding the default. The court stated, "The failure of the mobile home owner to pay the rent, or portion thereof, into the registry of the court as required herein constitutes an absolute waiver of the mobile home owner's defenses other than payment, and the park owner is entitled to an immediate default." This reinforces the importance of adhering to court orders in eviction cases.

However, the court did identify a scrivener's error in the judgment. While the judgment correctly indicated that a Judicial Default was entered against Saxon, it mistakenly cited section 83.60(2) of the Florida Statutes instead of the correct section 723.063(2). The appellate court noted that this citation error did not affect the substance of the judgment and ordered the lower court to amend the judgment to reflect the correct statute.

The court concluded, "Because the judgment correctly entered a judicial default against Mr. Saxon as required by section 723.063(2) but cited the wrong statute, we affirm the judgment but remand for the trial court to correct this scrivener's error with an amended judgment that cites the operative statute." This decision highlights the court's commitment to ensuring that judgments are not only correct in substance but also in their legal citations.

The impact of this ruling is significant for both tenants and mobile home park owners in Florida. It reinforces the necessity for tenants to comply with court orders regarding rent payments, as failure to do so can lead to swift eviction proceedings. Additionally, it emphasizes the importance of accurate legal documentation in court judgments, which can affect the enforcement of such rulings.

Going forward, this ruling may serve as a precedent for similar eviction cases in mobile home parks. Tenants must be aware that not adhering to court orders can result in the loss of defenses against eviction. For mobile home park owners, the decision provides a clear pathway to obtaining default judgments when tenants fail to pay rent as required.

As for what’s next, it remains unclear whether Saxon will seek further legal recourse. The court's ruling allows for the possibility of appeal regarding the scrivener's error correction, but details about any potential appeal were not available in the court filing. There are no related cases pending at this time.