Summary
The Florida First District Court of Appeal reversed a final summary judgment in a quiet title and declaratory judgment action concerning whether deeds conveyed beachfront parcels with littoral rights. The court held that conflicting extrinsic evidence and competing reasonable inferences regarding the deeds’ latent ambiguity created a genuine dispute of material fact that could not be resolved on summary judgment.
Topics
Practice areas
Questions Presented
- Whether the trial court improperly resolved at summary judgment the latent ambiguity in the deeds concerning whether the conveyed parcels extended to the Gulf of Mexico and included littoral rights.
- Whether conflicting extrinsic evidence and competing reasonable inferences concerning the grantor's intent created a genuine dispute of material fact precluding summary judgment.
Holdings
- Summary judgment was improper because the record contained conflicting evidence and competing reasonable inferences about whether the original conveyances extended to the Gulf of Mexico or instead conveyed fixed-depth parcels ending landward of the beach.
- The record did not compel a single legal conclusion about what Dune Allen intended to convey; a factfinder could conclude either that the conveyances extended to the Gulf or that they described fixed-depth parcels ending landward of the beach.
Key quotations
“Summary judgment is not designed to resolve disputed issues of fact. It merely serves to identify whether an issue of fact exists that must be resolved by trial.” (3)
“Credibility determinations, the weighing of evidence, and the drawing of legitimate inferences from the facts are jury functions, not those of a judge.” (3)
“A reasonable factfinder could conclude either that the conveyances extended to the Gulf or that they described fixed-depth parcels ending landward of the beach.” (6)
Factual background
The disputed parcels were part of a 143-acre Walton County tract acquired by E.C. Allen in 1925 and conveyed to Dune Allen in 1956. Dune Allen conveyed seven parcels between 1964 and 1970 by metes-and-bounds descriptions fixing the southern boundary by a 315-foot measured call from Highway 30A; the deeds did not refer to the Gulf of Mexico, the mean high-water line, or another water boundary. The appellees presented surveys, historical documents, and testimony supporting an inference that the conveyances extended to the Gulf, while Dune Allen presented contrary deed language, survey interpretations, and expert and lay testimony indicating that the parcels were fixed-depth parcels ending landward of the beach.
Procedural history
The appellees filed quiet-title and declaratory-judgment actions in 2023, alleging that Dune Allen's original conveyances extended their parcels to the Gulf of Mexico and included littoral rights. The parties filed competing summary-judgment motions. The circuit court found a latent ambiguity in the deeds, considered extrinsic evidence, and entered final summary judgment for the appellees; it denied Dune Allen's motion for rehearing. The First District reversed and remanded because conflicting evidence and competing reasonable inferences created a genuine dispute of material fact.
Remand instructions
The cause is remanded for further proceedings; the issue whether the conveyances extended to the Gulf or included littoral rights must be resolved through proceedings capable of determining the disputed facts.