1944 Beach Boulevard, LLC v. Live Oak Banking Company

Supreme Court of Florida ____________ No. SC21-1717 ____________ 1944 BEACH BOULEVARD, LLC, Appellant, vs. LIVE OAK BANKING COMPANY, Appellee. August 25, 2022 LAWSON, J. This case is before the Court for review of three questions of Florida law certified by the United States Court of Appeals for the Eleventh Circuit that are determinative of a cause pending in that court and for which there appears to be no controlling precedent. We have jurisdiction. See art. V, § 3(b)(6), Fla. Const. The certified questions concern the interpretation of section 679.5061(3), Florida Statutes (2021), which creates a safe harbor for financing statements that are otherwise ineffective to perfect a security interest because they fail to correctly name the debtor as required by Florida law. The safe harbor applies when a financing statement that fails to correctly name the debtor is disclosed by “a search of the records of the filing office under the debtor’s correct name, using the filing office’s standard search logic, if any.” § 679.5061(3). Collectively, the Eleventh Circuit’s questions ask us to delineate the proper scope of the “search” of the filing office’s records as that term is used in the safe harbor provision. See In re NRP Lease Holdings, LLC, 20 F.4th 746, 758 (11th Cir. 2021). However, as explained below, we find dispositive a threshold question that was not expressly addressed or certified by the Eleventh Circuit, namely: “Is the filing office’s use of a ‘standard search logic’ necessary to trigger the safe harbor protection of section 679.5061(3)?” Reading section 679.5061 in its entirety, our answer is yes. Because Florida’s filing office, the Florida Secured Transaction Registry, does not employ a “standard search logic,” we hold that the safe harbor cannot apply, which means that a financing statement that fails to correctly name the debtor as required by Florida law is “seriously misleading” and therefore ineffective. § 679.5061(2). Accordingly, it is unnecessary to reach -2- the Eleventh Circuit’s three certified questions concerning the proper scope of the “search” under the safe harbor provision. BACKGROUND 1944 Beach Boulevard, LLC (Beach Boulevard), is a limited liability company organized and existing under the laws of Florida. Beach Boulevard and its affiliates were jointly and severally indebted to Live Oak Banking Company (Live Oak) in the approximate amount of $3,000,000 on account of two loans, each in the original principal amount of $2,500,000. The two loans purport to be secured by a blanket lien on all of Beach Boulevard’s assets. To perfect its claimed security interests, Live Oak filed two UCC-1 Financing Statements with the Florida Secured Transaction Registry (Registry). However, the financing statements filed by Live Oak improperly name the debtor as “1944 Beach Blvd., LLC” instead of “1944 Beach Boulevard, LLC.” (Emphasis added.) On December 5, 2019, Beach Boulevard and its affiliates filed voluntary petitions for reorganization under Chapter 11 of the United States Bankruptcy Code. When Beach Boulevard’s manager conducted a search of the Registry, Live Oak’s financing statements did not appear on the page of twenty results generated by the -3- Registry. Live Oak’s financing statements did, however, appear on the immediately preceding page. Beach Boulevard filed a complaint in the bankruptcy court, which asserted that Live Oak’s financing statements failed to correctly name the debtor as required by Florida law, making the statements “seriously misleading” within the meaning of section 679.5061(2) and therefore ineffective to perfect Live Oak’s security interest. See In re NRP Lease Holdings, 20 F.4th at 750. Seeking the statutory safe harbor protection provided by section 679.5061(3) for financing statements that would otherwise be ineffective for failing to correctly name the debtor, see § 679.5061(2), Live Oak asserted in its answer to Beach Boulevard’s complaint the affirmative defense that “its financing statements substantially complied with Florida law and that abbreviating ‘Boulevard’ to ‘Blvd.’ was a minor error or omission that does not render the financing statements defective or seriously misleading.” In re NRP Lease Holdings, 20 F.4th at 751. Live Oak also “claimed that the filing statements were not ‘seriously misleading’ because they can be found within one page of the initial search results.” Id. In support, Live Oak explained that “while its liens do not appear on -4- the first page of results for a search in the Registry under ‘1944 Beach Boulevard, LLC,’ the search results are displayed in alphabetical order and ‘merely clicking the blue “<