Supreme Court of Florida

Anamaria Santiago, Petitioner v. Mauna Loa Investments, LLC, Respondent

March 17, 201641 Fla. L. Weekly Supp. 91

Summary

The court quashed the district court's decision because it improperly determined that the complaint failed to state a cause of action by considering a separate complaint and an attached deed outside the complaint under review. The court reaffirmed that complaint sufficiency is determined under the four-corners rule, including only the complaint and its attachments, and held that consolidation did not merge the separate actions. It also held that the defendant failed to establish excusable neglect necessary to set aside the default. No separate opinions were issued.