2026-09-10 · Florida · Courts

What happened. Florida's Fourth District Court of Appeal held that although Rule 1.222 lets a mobile homeowners' association sue in its own name on behalf of its members without meeting the ordinary class-action requirements, two associations may not combine into a single joint class action under that rule.

Wynne Building Corporation v. Spanish Lakes Country Club Village Homeowner's Association, Inc. and Spanish Lakes-Golf Village Homeowners Association, Inc., No. 4D2025-2169, was decided on 11 February 2026 (Lott, J., with a dissent), on nonfinal appeal from the St. Lucie Circuit Court.¹

The holding

“We hold that they may not; the rule allows one association to bring a given claim as a class action on behalf of its own members.”

The trial court had certified six counts as a single class because the lot-rent increases at issue “concern matters of common interest to all mobile park homeowners.” The majority held it “should have considered whether each association was permitted under the rule to bring its claims on behalf of its own membership.”

Certification was reversed — but the court was explicit that the trial court retains “broad discretion to join and consolidate related claims, including distinct Rule 1.222 class actions.”

The dissent's objection

The dissent argued that reversing “on a purely procedural sequencing issue—where the same claims will proceed before the same court through consolidation—does not advance the resolution of the dispute,” and “predictably increas[es] litigation costs and attorney's fees that, under the governing statutory framework, will ultimately be borne by the losing party.”

That is a fair description of the practical effect: the substance is unchanged, and the route to it is longer.

Why Rule 1.222 exists at all

Mobile-home residents occupy an unusual position in Florida law. They typically own the home and rent the lot beneath it, which makes them neither ordinary tenants nor ordinary homeowners. Chapter 723 gives their associations rights that condominium and homeowners' association members do not have — including, in defined circumstances, a right to purchase the park.

Rule 1.222 is the procedural counterpart: it lets the association litigate for its members without navigating Rule 1.220's class-certification machinery. Lot-rent increase challenges under s. 723.037 are the classic use.

1. Wynne Building Corporation v. Spanish Lakes Country Club Village Homeowner's Association, Inc., No. 4D2025-2169 (Fla. 4th DCA 11 February 2026) ↩
2. Prism Reports, reporting on the Li'l Abner Mobile Home Park evictions, 17 November 2025 ↩