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Lipman v. Vanowen Realty Corp.

Citations: 528 So. 2d 1384; 13 Fla. L. Weekly 1877; 1988 Fla. App. LEXIS 3537; 1988 WL 82528Docket: No. 87-2440

Court: District Court of Appeal of Florida; August 10, 1988; Florida; State Appellate Court

Narrative Opinion Summary

The court affirms in part and reverses in part the trial court's order. The reversal pertains specifically to the counts regarding declaratory relief and quiet title, which are reinstated. However, the dismissal of other counts is upheld. The court finds that the trial court mistakenly resolved the affirmative defense of unclean hands via a motion to dismiss. While unclean hands can be an affirmative defense, its application in this case was deemed premature due to a lack of evidentiary basis to assess its relevance or extent. Judges Anstead, Letts, and Walden concur with this decision.

Legal Issues Addressed

Affirmative Defense of Unclean Hands

Application: The court determined that the trial court erred in resolving the affirmative defense of unclean hands at the motion to dismiss stage due to insufficient evidence to evaluate its applicability.

Reasoning: The court finds that the trial court mistakenly resolved the affirmative defense of unclean hands via a motion to dismiss.

Declaratory Relief and Quiet Title Reinstatement

Application: The appellate court reverses the trial court's dismissal of the counts related to declaratory relief and quiet title, reinstating them for further proceedings.

Reasoning: The reversal pertains specifically to the counts regarding declaratory relief and quiet title, which are reinstated.

Premature Application of Unclean Hands

Application: The appellate court held that the defense of unclean hands was applied prematurely in the absence of an evidentiary basis to determine its relevance.

Reasoning: While unclean hands can be an affirmative defense, its application in this case was deemed premature due to a lack of evidentiary basis to assess its relevance or extent.