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Dyck-O'Neal, Inc. v. Lytle
Citations: 227 So. 3d 764; 2017 WL 4582741Docket: CASE NO. 1D17-1288
Court: District Court of Appeal of Florida; October 16, 2017; Florida; State Appellate Court
Affirmation of the lower court's ruling is stated, referencing Higgins v. Dyck-O’Neal, Inc., which establishes that a party cannot initiate a separate action for a deficiency judgment if the foreclosure complaint already requests it and the foreclosure court retains jurisdiction to issue such a judgment. Additionally, Dyck-O’Neal, Inc. v. Lanham is mentioned, which certifies a conflict between the decision in Higgins and rulings from other district courts of appeal. Justices Roberts, Bilbrey, and Kelsey concur with this opinion.