Badaraco v. Suncoast Towers V Associates
Docket: No. 95-2738
Court: District Court of Appeal of Florida; July 3, 1996; Florida; State Appellate Court
Carlos Badaraco, a tenant, appeals the dismissal of his class action complaint against his landlord, Suncoast Towers V Associates, seeking damages for interruptions in water and elevator services during renovations to convert the rental building into condominiums. Badaraco invokes Section 83.67 of the Florida Statutes (1995), which prohibits landlords from interrupting utility services and claims entitlement to three months' rent for each interruption. The statute specifies that landlords are liable for actual and consequential damages or three months' rent, whichever is greater, for violations. Badaraco argues that this creates an automatic entitlement to damages for each utility interruption, independent of its duration, purpose, or actual damages suffered. The court emphasizes the importance of legislative intent in statutory interpretation, noting that if a literal interpretation leads to unreasonable results, courts must consider broader legislative history and context. The court finds that the legislative intent behind Section 83.67 is to deter self-help eviction practices rather than penalize landlords for temporary utility interruptions related to necessary maintenance or improvements. Badaraco concedes that the landlord's actions were not aimed at coercing tenants to vacate but were part of legitimate repairs. Therefore, the court concludes that the trial court correctly dismissed the complaint, affirming the dismissal based on the understanding of legislative intent and the context of the statute's creation.