DAVID M. SANTIAGO v. WILMINGTON TRUST, NATIONAL ASSOCIATION, Not in Its Individual Capacity, but Solely as Trustee for MFRA TRUST 2015-1

• Court: District Court of Appeal of Florida
• Decided: January 30, 2026
• Docket: 6D2024-1562
• Status: Published

Opinion

SIXTH DISTRICT COURT OF APPEAL STATE OF FLORIDA _____________________________

Case No. 6D2024-1562 Lower Tribunal No. 2018-CA-005130 _____________________________

DAVID M. SANTIAGO,

Appellant, v.

WILMINGTON TRUST, NATIONAL ASSOCIATION, not in its individual capacity, but solely as Trustee for MFRA TRUST 2015-1, Appellee. _____________________________

Appeal from the Circuit Court for Orange County. Luis F. Calderon, Judge.

January 30, 2026

PRATT, J.

Appellant David M. Santiago appeals the trial court’s order granting summary

judgment in favor of Wilmington Trust, National Association, not in its individual

capacity, but solely as trustee for MFRA Trust 2015-1. We write solely to explain

why we reject Appellant’s argument regarding Florida Rule of Civil Procedure

1.510(a)’s statement-on-the-record requirement. 1

1 We reject without further discussion Appellant’s argument that his affirmative defenses precluded entry of summary judgment. Appellant asserts that the trial court’s written order failed to include sufficient

reasons for granting Appellee’s summary judgment motion pursuant to rule 1.510(a).

See generally Fla. R. Civ. P. 1.510(a) (“The court shall state on the record the reasons

for granting or denying the motion.”); In re Amends. to Fla. R. Civ. P. 1.510, 317

So. 3d 72, 77 (Fla. 2021) (“To comply with this requirement, it will not be enough

for the court to make a conclusory statement that there is or is not a genuine dispute

as to a material fact. The court must state the reasons for its decision with enough

specificity to provide useful guidance to the parties and, if necessary, to allow for

appellate review.”). However, Appellant’s argument fails to acknowledge that a trial

court can satisfy rule 1.510(a)’s statement-on-the-record requirement either “by

stating its reasons in the order granting final summary judgment or by oral

pronouncement.” Tucker v. LNV Corp., 363 So. 3d 1095, 1097 (Fla. 4th DCA 2023).

In this case, the trial court held a hearing on Appellee’s summary judgment motion.

Because the record on appeal does not include a transcript from the summary

judgment hearing, we “cannot determine whether the trial court satisfied the

‘statement on the record’ requirement via oral pronouncement.” Hardison v. Bank

of N.Y. Mellon, 399 So. 3d 1173, 1174 (Fla. 3d DCA 2024) (quoting Tucker, 363 So.

3d at 1098).

AFFIRMED.

STARGEL and MIZE, JJ., concur.

2 Anthony N. Legendre, II, of the Law Offices of Legendre & Legendre, PLLC, Maitland, for Appellant.

Eric M. Levine, of Atlas | Solomon, LLP, Stuart, for Appellee.

NOT FINAL UNTIL TIME EXPIRES TO FILE MOTION FOR REHEARING AND DISPOSITION THEREOF IF TIMELY FILED