Delacruz v. Wells Fargo Bank, N.A.

IN THE DISTRICT COURT OF APPEAL OF THE STATE OF FLORIDA FIFTH DISTRICT NOT FINAL UNTIL TIME EXPIRES TO FILE MOTION FOR REHEARING AND DISPOSITION THEREOF IF FILED JUANA DELACRUZ, Appellant, v. Case No. 5D15-2481 WELLS FARGO BANK, N.A., ET AL., Appellees. ________________________________/ Opinion filed January 20, 2017 Appeal from the Circuit Court for Lake County, Carven D. Angel, Senior Judge Mark P. Stopa, of Stopa Law Firm, Tampa, for Appellant. Sara F. Holladay-Tobias, Gabriel M. Hartsell and Emily Y. Rottmann, of McGuirewoods, LLP, Jacksonville, for Appellee, Wells Fargo Bank, N.A. No Appearance for Other Appellees. PER CURIAM. In this foreclosure case, on the threshold of the scheduled oral argument, Appellee conceded error, based in part on our recently released opinion in Palma v. J.P. Morgan Chase Bank, N.A., No. 5D15-3358 (Fla. 5th DCA Dec. 2, 2016). Palma settled the primary issue framed in this appeal—whether Appellant properly pled Appellee’s failure to comply with a precondition to acceleration as a defense. Appellant denied with specificity that Appellee had conducted a “face-to-face” interview, as required by the terms of the mortgage, but she did not label this defensive assertion as an “affirmative defense.” The trial court accepted Appellee’s argument that the unlabeled defense was not properly pled and deemed it waived. Although Palma settled the largely semantic issue upon which the trial court based its ruling, it failed to emphasize that pleading labels (or lack thereof) seldom control. Work v. Provine, 632 So. 2d 1119 (Fla. 1st DCA 1994). Where, as here, the factual basis for the defense provides sufficient notice to apprise the plaintiff of the precise basis for the defense, the failure to affix the correct label is not an impediment to a determination on the merits. Appellee also rightfully concedes that its failure to move into evidence the modification agreement was error on this record. Accordingly, we reverse and remand the judgment with instructions that the trial court enter an order of involuntary dismissal. REVERSED AND REMANDED. ORFINGER, TORPY, JJ., and THOMPSON, E. R., Senior Judge, concur. 2