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SANTANA EQUESTRIAN PRIVATE FINANCIAL, LLC v. TIFFANY RICHTMYER
Citation: Not availableDocket: 21-3363
Court: District Court of Appeal of Florida; September 14, 2022; Florida; State Appellate Court
Original Court Document: View Document
Santana Equestrian Private Financial, LLC is appealing a nonfinal order from the Circuit Court, which granted replevin of a competitive jumping horse to Tiffany Richtmyer. Santana Equestrian asserts it purchased the horse in good faith and in the ordinary course of business. The District Court of Appeal of Florida reversed the trial court's decision, citing the precedent set in Carlsen v. Rivera and the relevant provisions of Florida's Uniform Commercial Code (UCC), specifically section 672.403. This section states that a purchaser acquires all title from a transferor with voidable title, allowing good faith purchasers to obtain valid title despite potential issues with the original transaction, such as deception or dishonored checks. The UCC also defines a "Buyer in ordinary course of business" as someone who buys without knowledge of any conflicting rights. The court noted that Richtmyer had entrusted the horse to a merchant, who then either sold or entrusted it to another merchant for sale, thereby protecting Santana Equestrian's rights as a good faith buyer. The UCC's intent is to facilitate commerce by ensuring that good faith purchasers can acquire clear title. A year and a half after the initial entrustment, the second merchant sold a horse to Paulo Santana, the owner of Santana Equestrian. The trial court's conclusion that Santana was not a good faith buyer was unsupported by evidence. An expert witness testified that the sale was typical in the industry, noting that Santana Equestrian purchased from an established company and considered the horse's athletic ability and performance record. Santana reviewed performance videos and relied on input from his godson, a professional rider who had experience with the horse. The expert found the sales price and negotiations standard for the industry, indicating no irregularities in the transaction. The evidence confirmed that the sale adhered to customary practices in the jumping horse market, qualifying Santana as a good faith purchaser under the Uniform Commercial Code (UCC). Consequently, the court reversed the replevin judgment that awarded possession of the horse to Richtmyer, with concurring opinions from Judges Ciklin, Kuntz, and Artau. The decision is not final until a timely motion for rehearing is resolved.