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Brocklebank v. Eastern Financial Federal Credit Union

Citations: 634 So. 2d 171; 1994 Fla. App. LEXIS 1003; 1994 WL 45316Docket: No. 92-2495

Court: District Court of Appeal of Florida; February 14, 1994; Florida; State Appellate Court

Narrative Opinion Summary

Affirmation of summary judgment in favor of the lender is based on Section 687.0304 of the Florida Statutes (1991), which dictates that the lack of a written credit agreement precludes any action against the bank for claims related to an oral credit agreement. This conclusion aligns with precedents set in cases such as Griffiths v. Barnett Bank of Naples, AFM Corp. v. Southern Bell Tel. Tel. Co., Florida Power & Light Co. v. Westinghouse Electric Corp., Canell v. Areola Housing Corp., GAF Corp. v. Zack Co., and Ostman v. Lawn, reinforcing the necessity of a written contract in enforcing credit agreements.

Legal Issues Addressed

Precedent on Enforceability of Oral Credit Agreements

Application: The decision aligns with established precedents that reinforce the necessity of a written contract in enforcing credit agreements, emphasizing that oral agreements are not legally enforceable in such contexts.

Reasoning: This conclusion aligns with precedents set in cases such as Griffiths v. Barnett Bank of Naples, AFM Corp. v. Southern Bell Tel. Tel. Co., Florida Power & Light Co. v. Westinghouse Electric Corp., Canell v. Areola Housing Corp., GAF Corp. v. Zack Co., and Ostman v. Lawn, reinforcing the necessity of a written contract in enforcing credit agreements.

Requirement of Written Credit Agreement under Florida Statutes

Application: The court affirmed summary judgment in favor of the lender, holding that Section 687.0304 of the Florida Statutes precludes any action against the bank based on an oral credit agreement due to the absence of a written contract.

Reasoning: Affirmation of summary judgment in favor of the lender is based on Section 687.0304 of the Florida Statutes (1991), which dictates that the lack of a written credit agreement precludes any action against the bank for claims related to an oral credit agreement.