Luis R. Mercado v. Jayanth Sridhar

CourtDistrict Court of Appeal of Florida
DecidedNovember 15, 2023
Docket2023-0223
StatusPublished

This text of Luis R. Mercado v. Jayanth Sridhar (Luis R. Mercado v. Jayanth Sridhar) is published on Counsel Stack Legal Research, covering District Court of Appeal of Florida primary law. Counsel Stack provides free access to over 12 million legal documents including statutes, case law, regulations, and constitutions.

Bluebook
Luis R. Mercado v. Jayanth Sridhar, (Fla. Ct. App. 2023).

Opinion

Third District Court of Appeal State of Florida

Opinion filed November 15, 2023. Not final until disposition of timely filed motion for rehearing.

________________

No. 3D23-0223 Lower Tribunal No. 22-1195 ________________

Luis R. Mercado, et al., Appellants,

vs.

Jayanth Sridhar, et al., Appellees.

An Appeal from the Circuit Court for Miami-Dade County, Carlos Guzman, Judge.

Arnaldo Vélez, P.A., and Arnaldo Vélez, for appellants.

Holland & Knight LLP, and Joshua R. Levenson (Fort Lauderdale), Christopher Bellows and Jordan N. Bittle (Fort Lauderdale), for appellees.

Before FERNANDEZ, SCALES and MILLER, JJ.

SCALES, J. In this action involving the sale and purchase of real property,

appellants Luis R. Mercado and Chanttel Mercado (“Sellers”), the

defendants/counter-plaintiffs below, appeal a January 9, 2023 final summary

judgment in favor of appellees Jayanth Sridhar and Nika Bagheri (“Buyers”),

the plaintiffs/counter-defendants below, on (i) Buyers’ claim for specific

performance, and (ii) Sellers’ counterclaim for slander of title. The trial court

entered the judgment after concluding that the parties had executed a valid

and enforceable agreement for Buyers’ purchase of Sellers’ home. Finding

no error, we affirm the challenged final summary judgment.

I. RELEVANT FACTS AND PROCEDURAL BACKGROUND

On January 21, 2022, Buyers filed this action in the Miami-Dade

County Circuit Court seeking specific performance of a fully executed

contract for the sale and purchase of a residential home using the standard

form approved by the Florida Association of Realtors and the Florida Bar

(“Form Agreement”). Sellers’ responsive pleading denied that the parties had

entered into an enforceable contract and included a counterclaim alleging

that Buyers’ recordation of a lis pendens had slandered the title to Sellers’

home.

In April 2022, Buyers moved for summary judgment, arguing that,

because the Form Agreement contained all of the requirements of a contract,

2 was executed by the parties, contained an integration clause, and did not

expressly incorporate Buyers’ proposed addendum (made in Buyer’s offer)

or Seller’s proposed, revised addendum (made in Sellers’ counteroffer), the

Form Agreement – while proposed and negotiated1 contemporaneously with

an addendum thereto – constituted the entire agreement between the

parties. According to Buyers, the parties had come to an express agreement

on the terms of Buyers’ purchase of the real property, but simply failed to

agree upon the terms of, and failed to execute, a stand-alone agreement

covering Buyers’ purchase of the home’s furnishings and Sellers’ leaseback

option.

Sellers also moved for summary judgment, arguing that the fully

executed Form Agreement was not enforceable because the parties had not

reached a meeting of the minds regarding the issues contained in the

addendum (regarding the home’s furniture and a leaseback option), and that

those addendum issues were essential to the formation of the contract.

According to Sellers, such an addendum was sufficiently incorporated by

reference into the Form Agreement because both Buyers (with the offer) and

1 The only change made to the face of the Form Agreement during the parties’ negotiations was to the purchase price, with parties agreeing upon $3.2 million.

3 Sellers (with the counteroffer) had “attached” their competing versions of an

addendum to the Form Agreement when they made their respective offers.

After holding a hearing on the parties’ competing summary judgment

motions, the trial court entered the challenged January 9, 2023 final

summary judgment in favor of Buyers on Buyers’ claim for specific

performance and Sellers’ counterclaim for slander of title. The judgment

directed the parties to proceed to closing on the home for the purchase price

of $3.2 million. Sellers timely appealed this January 9, 2023 judgment.

II. ANALYSIS2

A. Issue on Appeal

The parties do not dispute that the Form Agreement, a residential real

estate contract approved by the Florida Association of Realtors and the

Florida Bar, satisfied the requirements of legal contract formation and, if

considered alone, constituted a valid and enforceable agreement. The

primary issue in this appeal, therefore, is whether it was proper for the trial

court to enforce the Form Agreement without regard to a contemporaneously

negotiated, but unexecuted, addendum that, had it been agreed to by the

2 “[A] trial court’s decision construing a contract presents an issue of law that is subject to the de novo standard of review.” Hammond v. DSY Developers, LLC, 951 So. 2d 985, 988 (Fla. 3d DCA 2007). And we review de novo an order granting final summary judgment. Id.

4 parties, would have added additional terms not contained in the Form

Agreement. Put another way, the issue is whether the trial court erred by

concluding that the fully executed Form Agreement constituted an

enforceable contract without regard to the unexecuted addenda that the trial

court determined had not been incorporated into the Form Agreement.

In the challenged judgment, the trial court determined that an

unexecuted addendum was not part of the Form Agreement because,

“[p]ursuant to the plain terms of the [Form Agreement], in order for the parties

to elect that an addendum was to be included, that election must be made

within the 12 pages of the Contract itself.” Therefore, the lower court

determined, the fully executed Form Agreement constituted a valid and

enforceable agreement, despite the parties failing to come to an agreement

on the collateral issues covered by the addendum.

B. This Court’s Muñiz decision

In the challenged judgment, the trial court relied heavily upon this

Court’s decision in Muñiz v. Crystal Lake Project, LLC, 947 So. 2d 464 (Fla.

3d DCA 2006), which we find instructive to our analysis.

In Muñiz, a home builder provided prospective purchasers with an

unexecuted agreement for the construction and sale of a model home. The

purchasers signed the agreement and made a separate list of additional

5 options that the purchasers believed should be included in the subject

property. Id. at 467. Although the purchasers provided their “additional

option[s] list” to the builder along with their signed copy of the agreement,

the purchasers’ additional options list was neither added to nor incorporated

by reference into the purchase agreement. Id. The builder then signed the

agreement, resulting in a fully executed contract. Id. 3

For reasons not relevant here, the builder sought to cancel the

agreement during construction, which led to the purchasers filing an action

for specific performance. The trial court declined to enforce the contract,

concluding, in part, that the parties’ failure to agree upon the purchasers’

additional options list rendered the agreement’s terms unclear, indefinite,

uncertain and incomplete. Id. at 469. On appeal, this Court reversed, holding

that the trial court erred in denying the purchasers’ claim for specific

performance.

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Related

General Impact Glass & Windows Corp. v. Rollac Shutter of Texas, Inc.
8 So. 3d 1165 (District Court of Appeal of Florida, 2009)
Hammond v. DSY DEVELOPERS, LLC
951 So. 2d 985 (District Court of Appeal of Florida, 2007)
Jenkins v. Eckerd Corp.
913 So. 2d 43 (District Court of Appeal of Florida, 2005)
Muniz v. Crystal Lake Project, LLC
947 So. 2d 464 (District Court of Appeal of Florida, 2006)
Duval Motors Co. v. Rogers
73 So. 3d 261 (District Court of Appeal of Florida, 2011)

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Luis R. Mercado v. Jayanth Sridhar, Counsel Stack Legal Research, https://law.counselstack.com/opinion/luis-r-mercado-v-jayanth-sridhar-fladistctapp-2023.