Dyck-O'Neal, Inc. v. Lanham

Because the circuit court lacked subject matter jurisdiction to consider Appellant’s independent action at law for a deficiency decree in this post-foreclosure proceeding, the order on appeal is void, and hereby quashed. See Higgins v. Dyck-O’Neal, Inc., 201 So.3d 157, 166-67 (Fla. 1st DCA 2016) (holding that a party is not entitled to pursue a separate action for deficiency judgment where the foreclosure complaint includes a prayer for a deficiency judgment and the foreclosure court reserves jurisdiction to enter a deficiency judgment). In so ruling, we certify conflict with Garcia v.…