A Florida court recently ruled in a commercial lease dispute involving First Care Therapy, LLC, and Loodjhinssy Lafaille-Paul against Congress Ave Boynton, LLC. The court affirmed the liability of the tenant and guarantor but reversed the damages awarded due to procedural errors. This case highlights the importance of proper legal procedures in commercial lease agreements.

The case, filed under docket number 4D2025-2466, revolves around a breach of a commercial lease and guaranty. The ruling affects both the tenant, First Care Therapy, and the guarantor, Lafaille-Paul, as they face financial repercussions due to the judgment. The decision underscores the need for landlords and tenants to adhere to legal protocols when disputes arise.

Background

First Care Therapy, LLC, the tenant in this case, entered into a lease agreement for commercial premises in Boynton Beach in September 2021. Loodjhinssy Lafaille-Paul, as the guarantor, agreed to cover the tenant's obligations under the lease. In May 2024, Congress Ave Boynton, LLC purchased the property and became the new landlord after the lease was assigned to them.

In February 2025, Congress Ave Boynton filed a lawsuit against First Care Therapy and Lafaille-Paul, claiming nonpayment of rent. The complaint did not specify a fixed amount owed but instead detailed various charges including base rent, operating expenses, and late fees. The landlord sought a total of $85,782.80 based on an affidavit that calculated the damages, which included costs related to re-letting the premises.

The Ruling

The District Court of Appeal of Florida ruled on November 12, 2026, affirming the trial court's judgment regarding the landlord's standing, the trial court's jurisdiction, and the liability of the appellants for breach of the lease and guaranty. The court stated, "We are unpersuaded by Appellants’ principal arguments—that the complaint failed to state a cause of action, Landlord lacked standing, and the trial court therefore lacked subject matter jurisdiction."

However, the court reversed the damages award, emphasizing that unliquidated damages cannot be awarded without a properly noticed trial. The court noted, "The trial court erred by awarding unliquidated damages in the final default summary judgment without a properly noticed damages trial, because the amount awarded could not be determined with exactness from the pleadings." Judges Forst, Shepherd, and Shaw concurred in the decision.

Impact

This ruling has significant implications for future commercial lease disputes in Florida. It reinforces the necessity for landlords to follow proper legal procedures when seeking damages for unpaid rent. The court's decision to reverse the damages award highlights the importance of conducting a properly noticed trial for unliquidated damages, which require evidence to establish the amount owed.

Landlords and tenants alike must be aware of the legal requirements surrounding lease agreements and the consequences of failing to adhere to them. This case serves as a reminder that procedural missteps can lead to significant changes in the outcome of a case, particularly in financial matters.

What's Next

The court has remanded the case for a properly noticed damages trial to determine the unliquidated damages owed by the tenant and guarantor. It remains to be seen whether the appellants will appeal the ruling further or if there are any related cases pending that could influence this matter.