Rodriguez v. Federal National Mortgage Ass'n

The issue in this case is whether the trial court erred in entering an order disbursing surplus proceeds from a foreclosure sale to the buyer to use to satisfy subordinate lienholders who were not parties to the foreclosure action. Because the issue is purely a question of law, our review is de novo. See Armstrong v. Harris, 773 So.2d 7, 11 (Fla. 2000).

Federal National Mortgage Association (“FNMA”) brought a foreclosure action against Carlos M. Rodriguez and Rafael Rodriguez, the property owners. No subordinate lienholders were named in the foreclosure complaint. In time, a final judgment was…