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C&J Global Invs., Inc. v. JVS Contracting, Inc.

Citation: 240 So. 3d 68Docket: Case No. 2D16–4857

Court: District Court of Appeal of Florida; February 13, 2018; Florida; State Appellate Court

Narrative Opinion Summary

In this case, C&J Global Investments, Inc. sued multiple defendants to invalidate a warranty deed in favor of Capgain Properties, Inc., seeking rescission and quiet title. Additionally, it challenged a second deed to JVS Contracting, Inc. as a 'wild deed' and sought damages for unauthorized entry. JVS cross-claimed for reformation of the second deed, citing an error. C&J Global's motion to intervene in this cross-claim was denied, a decision it appealed. The court found that C&J Global lacked a direct and immediate interest in the reformation cross-claim, as required by Florida Rule of Civil Procedure 1.230. The potential impact on C&J's ownership interest was contingent on voiding the first deed, rendering its interest indirect and insufficient for intervention. The ruling emphasized that intervention necessitates a direct and immediate interest, not an uncertain or contingent one. The denial of the motion to intervene was affirmed by the appellate court, as the trial court did not err in its judgment.

Legal Issues Addressed

Effect of Reformation on Prior Conveyances

Application: The judgment reforming the second deed would not immediately impact C&J Global's claimed interest, which is contingent upon voiding the first deed.

Reasoning: A judgment reforming the second deed would not immediately affect its claimed interest, as C&J Global must first successfully void the first deed.

Intervention under Florida Rule of Civil Procedure 1.230

Application: The court determined that C&J Global Investments, Inc. lacked a direct and immediate interest in the reformation cross-claim, thus denying its motion to intervene.

Reasoning: The court concluded that C&J Global lacked a direct and immediate interest in the reformation cross-claim, affirming the denial.

Requirements for Intervention

Application: The court emphasized that a mere indirect or contingent interest does not satisfy the criteria for intervention in pending litigation.

Reasoning: The court emphasized that a mere indirect or contingent interest is insufficient for intervention.