A recent ruling from the District Court of Appeal of Florida has significant implications for a premises liability case involving Howey Mansion, LLC, and Blush by Brandee Gaar, LLC. The court affirmed the trial court's decision to grant summary judgment in favor of the defendants while also reversing a previous denial of costs to Howey Mansion. This ruling affects the parties involved and clarifies aspects of Florida's liability laws.
The case, known as Howey Mansion, LLC D/B/A Florida Oranges, LLC D/B/A the Howey Mansion, LLC v. Anna Puett and Blush by Brandee Gaar, LLC, was filed under docket number 5D2025-1766. It stems from a premises liability claim brought by Anna Puett against Howey Mansion and Blush. The dispute revolves around whether the defendants were liable for an incident that occurred on their property.
In this case, Anna Puett, the appellant, claimed that she suffered injuries due to unsafe conditions at the Howey Mansion. The defendants, Howey Mansion and Blush, argued that they were not responsible for her injuries. The trial court reviewed the evidence and granted summary judgment, meaning it found that there was not enough evidence for a trial, and the defendants were entitled to win as a matter of law.
The case reached the District Court of Appeal after Puett appealed the trial court's decision. Her appeal included challenges to the summary judgment and the denial of costs requested by Howey Mansion. The court consolidated this appeal with two other related cases, indicating that they all arose from the same premises liability claim.
On August 7, 2026, the court issued its ruling. The judges affirmed the trial court's summary judgment in favor of Howey Mansion and Blush, stating that the evidence was "so one-sided" that the defendants were entitled to prevail. The court noted, "The trial judge correctly entered the judgments because the evidence was 'so one-sided' that Howey Mansion and Blush were entitled to 'prevail as a matter of law.'" This ruling confirms that the defendants did not have liability in this case.
Additionally, the court affirmed the trial court's denial of Howey Mansion's motion for attorney's fees. The judges explained that the joint proposal of settlement required Puett to settle with both offerors, and since only one of the joint offerors obtained a judgment, the request for attorney's fees was denied.
However, the court reversed the trial court's denial of Howey Mansion's motion for costs. The judges cited Florida Statutes, specifically section 57.041, which states that the "party recovering judgment shall recover all his or her legal costs and charges." The court emphasized that the statutory language is "unambiguous" and that Howey Mansion, having recovered judgment, is entitled to its lawful costs. The ruling stated, "The statute demands that the party recovering judgment be awarded costs." This part of the ruling clarifies the entitlement of parties to recover costs after winning a judgment.
This ruling has important implications for future premises liability cases in Florida. It reinforces the standard that defendants can prevail in liability claims if the evidence is overwhelmingly in their favor. The decision also highlights the importance of understanding the legal framework regarding costs and attorney's fees in such cases. Parties involved in similar disputes may look to this ruling as a guide for their own legal strategies.
The impact of this ruling extends beyond the immediate parties involved. It sets a precedent regarding the interpretation of Florida's cost recovery statute, which may influence how future courts handle similar requests for costs in liability cases. This ruling may encourage defendants to pursue summary judgment more aggressively when they believe the evidence is in their favor.
Looking ahead, it remains to be seen whether Anna Puett will seek further legal recourse, such as appealing the ruling to the Florida Supreme Court. The court's decision is not final until the disposition of any timely and authorized motion under Florida Rules of Appellate Procedure 9.330 or 9.331. Therefore, the case could still have further developments.