Fourth DCA Upholds Summary Judgment for Condominium Association

CSK Appellate Counsel
Orlando Associate Michael Andriano

Case Summary
This appeal arose from a contract dispute involving condominium unit owners and a condominium association. The Plaintiffs claimed that the Defendant Association became contractually responsible for discounted products offered to residents through a third-party vendor.

The trial court entered partial final summary judgment in favor of the Defendant after finding that no contract existed between the Association and the Plaintiffs. The Plaintiffs appealed, arguing that the Association’s involvement in coordinating the bulk-purchase opportunity created a contractual relationship.

Appellate Strategy
Mr. Andriano focused on the difference between helping coordinate a third-party program and becoming a party to a contract. He argued that while the Defendant helped residents access the vendor’s discounted products, it did not take on the vendor’s responsibilities or enter into an agreement with the unit owners.

Based on the association’s limited role, Mr. Andriano maintained that its involvement in the program was not enough to create an enforceable contract with the Plaintiffs and that the trial court’s ruling should be upheld.

Outcome
The Fourth District Court of Appeal affirmed the trial court’s partial final summary judgment in favor of the Defendant condominium association, leaving the finding of no contractual liability in place.

The decision highlights the importance of clearly defining the roles of community associations when coordinating programs with outside vendors. Helping residents access third-party products or services does not, on its own, create contractual obligations for an association