Florida Statutes

Fla. Stat. § 718.1255 (2025)

Alternative dispute resolution; mediation; nonbinding arbitration; applicability.

✓ 2025 Florida Statutes — current through the 2025 Regular Session

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718.1255 Alternative dispute resolution; mediation; nonbinding arbitration; applicability.—

¹(1) DEFINITIONS.—As used in this section, the term “dispute” means any disagreement between two or more parties that involves:

(a) The authority of the board of directors, under this chapter or association document, to:

1. Require any owner to take any action, or not to take any action, involving that owner’s unit or the appurtenances thereto.

2. Alter or add to a common area or element.

(b) The failure of a governing body, when required by this chapter or an association document, to:

1. Properly conduct elections.

2. Give adequate notice of meetings or other actions.

3. Properly conduct meetings.

4. Allow inspection of books and records.

“Dispute” does not include any disagreement that primarily involves: title to any unit or common element; the interpretation or enforcement of any warranty; the levy of a fee or assessment, or the collection of an assessment levied against a party; the eviction or other removal of a tenant from a unit; alleged breaches of fiduciary duty by one or more directors; or claims for damages to a unit based upon the alleged failure of the association to maintain the common elements or condominium property.

(2) MEDIATION.—Mediation through Citizen Dispute Settlement Centers as provided for in s. 44.201 is encouraged.

(3) LEGISLATIVE FINDINGS.—

(a) The Legislature finds that unit owners are frequently at a disadvantage when litigating against an association. Specifically, a condominium association, with its statutory assessment authority, is often more able to bear the costs and expenses of litigation than the unit owner who must rely on his or her own financial resources to satisfy the costs of litigation against the association.

(b) The Legislature finds that alternative dispute resolution has been making progress in reducing court dockets and trials and in offering a more efficient, cost-effective option to court litigation. However, the Legislature also finds that alternative dispute resolution should not be used as a mechanism to encourage the filing of frivolous or nuisance suits.

(c) There exists a need to develop a flexible means of alternative dispute resolution that directs disputes to the most efficient means of resolution.

(d) The high cost and significant delay of circuit court litigation faced by unit owners in the state can be alleviated by requiring nonbinding arbitration and mediation in appropriate cases, thereby reducing delay and attorney fees while preserving the right of either party to have its case heard by a jury, if applicable, in a court of law.

(4) NONBINDING ARBITRATION AND MEDIATION OF DISPUTES.—The Division of Florida Condominiums, Timeshares, and Mobile Homes of the Department of Business and Professional Regulation may employ full-time attorneys to act as arbitrators to conduct the arbitration hearings provided by this chapter. The division may also certify attorneys who are not employed by the division to act as arbitrators to conduct the arbitration hearings provided by this chapter. A person may not be employed by the department as a full-time arbitrator unless he or she is a member in good standing of The Florida Bar. A person may only be certified by the division to act as an arbitrator if he or she has been a member in good standing of The Florida Bar for at least 5 years and has mediated or arbitrated at least 10 disputes involving condominiums in this state during the 3 years immediately preceding the date of application, mediated or arbitrated at least 30 disputes in any subject area in this state during the 3 years immediately preceding the date of application, or attained board certification in real estate law or condominium and planned development law from The Florida Bar. Arbitrator certification is valid for 1 year. An arbitrator who does not maintain the minimum qualifications for initial certification may not have his or her certification renewed. The department may not enter into a legal services contract for an arbitration hearing under this chapter with an attorney who is not a certified arbitrator unless a certified arbitrator is not available within 50 miles of the dispute. The department shall adopt rules of procedure to govern such arbitration hearings including mediation incident thereto. The decision of an arbitrator is final; however, a decision is not deemed final agency action. Nothing in this provision shall be construed to foreclose parties from proceeding in a trial de novo unless the parties have agreed that the arbitration is binding. If judicial proceedings are initiated, the final decision of the arbitrator is admissible in evidence in the trial de novo.

(a) Before the institution of court litigation, a party to a dispute, other than an election or recall dispute, shall either petition the division for nonbinding arbitration or initiate presuit mediation as provided in subsection (5). Arbitration is binding on the parties if all parties in arbitration agree to be bound in a writing filed in arbitration. The petition must be accompanied by a filing fee in the amount of $50. Filing fees collected under this section must be used to defray the expenses of the alternative dispute resolution program.

(b) The petition must recite, and have attached thereto, supporting proof that the petitioner gave the respondents:

1. Advance written notice of the specific nature of the dispute;

2. A demand for relief, and a reasonable opportunity to comply or to provide the relief; and

3. Notice of the intention to file an arbitration petition or other legal action in the absence of a resolution of the dispute.

Failure to include the allegations or proof of compliance with these prerequisites requires dismissal of the petition without prejudice.

(c) Upon receipt, the petition shall be promptly reviewed by the division to determine the existence of a dispute and compliance with the requirements of paragraphs (a) and (b). If emergency relief is required and is not available through arbitration, a motion to stay the arbitration may be filed. The motion must be accompanied by a verified petition alleging facts that, if proven, would support entry of a temporary injunction, and if an appropriate motion and supporting papers are filed, the division may abate the arbitration pending a court hearing and disposition of a motion for temporary injunction.

(d) Upon determination by the division that a dispute exists and that the petition substantially meets the requirements of paragraphs (a) and (b) and any other applicable rules, the division shall assign or enter into a contract with an arbitrator and serve a copy of the petition upon all respondents. The arbitrator shall conduct a hearing within 30 days after being assigned or entering into a contract unless the petition is withdrawn or a continuance is granted for good cause shown.

(e) Before or after the filing of the respondents’ answer to the petition, any party may request that the arbitrator refer the case to mediation under this section and any rules adopted by the division. Upon receipt of a request for mediation, the division shall promptly contact the parties to determine if there is agreement that mediation would be appropriate. If all parties agree, the dispute must be referred to mediation. Notwithstanding a lack of an agreement by all parties, the arbitrator may refer a dispute to mediation at any time.

(f) Upon referral of a case to mediation, the parties must select a mutually acceptable mediator. To assist in the selection, the arbitrator shall provide the parties with a list of both volunteer and paid mediators that have been certified by the division under s. 718.501. If the parties are unable to agree on a mediator within the time allowed by the arbitrator, the arbitrator shall appoint a mediator from the list of certified mediators. If a case is referred to mediation, the parties shall attend a mediation conference, as scheduled by the parties and the mediator. If any party fails to attend a duly noticed mediation conference, without the permission or approval of the arbitrator or mediator, the arbitrator must impose sanctions against the party, including the striking of any pleadings filed, the entry of an order of dismissal or default if appropriate, and the award of costs and attorney fees incurred by the other parties. Unless otherwise agreed to by the parties or as provided by order of the arbitrator, a party is deemed to have appeared at a mediation conference by the physical presence of the party or its representative having full authority to settle without further consultation, provided that an association may comply by having one or more representatives present with full authority to negotiate a settlement and recommend that the board of administration ratify and approve such a settlement within 5 days from the date of the mediation conference. The parties shall share equally the expense of mediation, unless they agree otherwise.

(g) The purpose of mediation as provided for by this section is to present the parties with an opportunity to resolve the underlying dispute in good faith, and with a minimum expenditure of time and resources.

(h) Mediation proceedings must generally be conducted in accordance with the Florida Rules of Civil Procedure, and these proceedings are privileged and confidential to the same extent as court-ordered mediation. Persons who are not parties to the dispute are not allowed to attend the mediation conference without the consent of all parties, with the exception of counsel for the parties and corporate representatives designated to appear for a party. If the mediator declares an impasse after a mediation conference has been held, the arbitration proceeding terminates, unless all parties agree in writing to continue the arbitration proceeding, in which case the arbitrator’s decision shall be binding or nonbinding, as agreed upon by the parties; in the arbitration proceeding, the arbitrator shall not consider any evidence relating to the unsuccessful mediation except in a proceeding to impose sanctions for failure to appear at the mediation conference. If the parties do not agree to continue arbitration, the arbitrator shall enter an order of dismissal, and either party may institute a suit in a court of competent jurisdiction. The parties may seek to recover any costs and attorney fees incurred in connection with arbitration and mediation proceedings under this section as part of the costs and fees that may be recovered by the prevailing party in any subsequent litigation.

(i) Arbitration shall be conducted according to rules adopted by the division. The filing of a petition for arbitration shall toll the applicable statute of limitations.

(j) At the request of any party to the arbitration, the arbitrator shall issue subpoenas for the attendance of witnesses and the production of books, records, documents, and other evidence and any party on whose behalf a subpoena is issued may apply to the court for orders compelling such attendance and production. Subpoenas shall be served and shall be enforceable in the manner provided by the Florida Rules of Civil Procedure. Discovery may, in the discretion of the arbitrator, be permitted in the manner provided by the Florida Rules of Civil Procedure. Rules adopted by the division may authorize any reasonable sanctions except contempt for a violation of the arbitration procedural rules of the division or for the failure of a party to comply with a reasonable nonfinal order issued by an arbitrator which is not under judicial review.

(k) The arbitration decision shall be rendered within 30 days after the hearing and presented to the parties in writing. An arbitration decision is final in those disputes in which the parties have agreed to be bound. An arbitration decision is also final if a complaint for a trial de novo is not filed in a court of competent jurisdiction in which the condominium is located within 30 days. The right to file for a trial de novo entitles the parties to file a complaint in the appropriate trial court for a judicial resolution of the dispute. The prevailing party in an arbitration proceeding shall be awarded the costs of the arbitration and reasonable attorney fees in an amount determined by the arbitrator. Such an award shall include the costs and reasonable attorney fees incurred in the arbitration proceeding as well as the costs and reasonable attorney fees incurred in preparing for and attending any scheduled mediation. An arbitrator’s failure to render a written decision within 30 days after the hearing may result in the cancellation of his or her arbitration certification.

(l) The party who files a complaint for a trial de novo shall be assessed the other party’s arbitration costs, court costs, and other reasonable costs, including attorney fees, investigation expenses, and expenses for expert or other testimony or evidence incurred after the arbitration hearing if the judgment upon the trial de novo is not more favorable than the arbitration decision. If the judgment is more favorable, the party who filed a complaint for trial de novo shall be awarded reasonable court costs and attorney fees.

(m) Any party to an arbitration proceeding may enforce an arbitration award by filing a petition in a court of competent jurisdiction in which the condominium is located. A petition may not be granted unless the time for appeal by the filing of a complaint for trial de novo has expired. If a complaint for a trial de novo has been filed, a petition may not be granted with respect to an arbitration award that has been stayed. If the petition for enforcement is granted, the petitioner shall recover reasonable attorney fees and costs incurred in enforcing the arbitration award. A mediation settlement may also be enforced through the county or circuit court, as applicable, and any costs and fees incurred in the enforcement of a settlement agreement reached at mediation must be awarded to the prevailing party in any enforcement action.

¹(5) PRESUIT MEDIATION.—In lieu of the initiation of nonbinding arbitration as provided in subsections (1)-(4), a party may submit a dispute to presuit mediation in accordance with s. 720.311; however, election and recall disputes are not eligible for mediation and such disputes must be arbitrated by the division or filed in a court of competent jurisdiction.

(6) DISPUTES INVOLVING ELECTION IRREGULARITIES.—Every arbitration petition received by the division and required to be filed under this section challenging the legality of the election of any director of the board of administration must be handled on an expedited basis in the manner provided by the division’s rules for recall arbitration disputes.

(7) APPLICABILITY.—This section does not apply to a nonresidential condominium unless otherwise specifically provided for in the declaration of the nonresidential condominium.

History.—s. 4, ch. 82-199; s. 4, ch. 85-60; s. 10, ch. 91-103; s. 5, ch. 91-426; s. 7, ch. 92-49; s. 232, ch. 94-218; s. 12, ch. 94-350; s. 37, ch. 95-274; s. 859, ch. 97-102; s. 2, ch. 97-301; s. 12, ch. 2002-27; s. 14, ch. 2008-28; s. 47, ch. 2008-240; s. 3, ch. 2014-74; s. 2, ch. 2015-175; s. 4, ch. 2017-188; s. 8, ch. 2021-99; s. 7, ch. 2023-203.

¹Note.—Section 7, ch. 2023-203, added paragraph (1)(d) and amended subsection (5), effective July 1, 2027, to read:

(d) The failure of a board of administration, when required by this chapter or an association document, to:

1. Obtain the milestone inspection required under s. 553.899.

2. Obtain a structural integrity reserve study required under s. 718.112(2)(g).

3. Fund reserves as required for an item identified in s. 718.112(2)(g).

4. Make or provide necessary maintenance or repairs of condominium property recommended by a milestone inspection or a structural integrity reserve study.

* * * * *

(5) PRESUIT MEDIATION.—In lieu of the initiation of nonbinding arbitration as provided in subsections (1)-(4), a party may submit a dispute to presuit mediation in accordance with s. 720.311; however, election and recall disputes are not eligible for mediation and such disputes must be arbitrated by the division or filed in a court of competent jurisdiction. Disputes identified in paragraph (1)(d) are not subject to nonbinding arbitration under subsection (4) and must be submitted to presuit mediation in accordance with s. 720.311.

Notes of Decisions

Cited in 50 cases (10 in the last 5 years), 1995–2025 · leading case: Neate v. Cypress Club Condo., Inc., 718 So. 2d 390 (Fla. 4th DCA 1998).

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Neate v. Cypress Club Condo., Inc., 718 So. 2d 390 (Fla. 4th DCA 1998). · cites it 23× “NOTES [1] § 718.1255 Fla. Stat. (1989). [2] The statute was later amended without substantial change to these provisions.”

NAT. VENTURES, INC. v. Water Glades 300 Condo. Ass'n, 847 So. 2d 1070 (Fla. 4th DCA 2003). · cites it 12× “§ 718.1255, Fla. Stat. (1995). Pursuant to the legislature's 1997 amendment of section 718.”

Gomez v. Fradin, 41 So. 3d 1068 (Fla. 4th DCA 2010). · cites it 6× “See § 718.1255(1), Fla. Stat. (2009). The term “dispute” does not, however, include “breaches of fiduciary duty by one or more directors.”

Carlandia Corp. v. Obernauer, 695 So. 2d 408 (Fla. 4th DCA 1997). · cites it 17× “The question posed in this case is whether section 718.1255, Florida Statutes (Supp.”

Brindise v. U.S. Bank Nat'l Ass'n, 183 So. 3d 1215 (Fla. 2d DCA 2016). · cites it 3× “§ 718.1255 (4), Fla. Stat. (2014). The Legislature knows how to create a condition precedent.”

Palisades Owners' Ass'n, Inc v. Thomas F. Browning, 247 So. 3d 589 (Fla. 1st DCA 2018). · cites it 15× “The Association moved to dismiss the complaint, arguing that Browning was required to submit his claim to nonbinding arbitration pursuant to section 718.1255, Florida Statutes (2016), before filing suit because the disagreement between the parties was a garden-variety dispute…”

Habitat II Condo., Inc. v. Kerr, 948 So. 2d 809 (Fla. 4th DCA 2007). · cites it 8× “In section 718.1255, Florida Statutes (2005), the Florida Legislature provided a non-binding arbitration mechanism for resolving most issues which arise between a condominium association and individual unit owners.”

Ruffin v. Kingswood E. Condo. Ass'n, 719 So. 2d 951 (Fla. 4th DCA 1998). · cites it 5× “("Association"), brought an arbitration proceeding under section 718.1255, Florida Statutes (1995), against unit owner Mary Ruffin and her son, appellant Paul Ruffin, alleging that because of physical altercations on the Association's premises involving appellant, who the…”

Blum v. Tamarac Fairways Ass'n, Inc., 684 So. 2d 826 (Fla. 4th DCA 1996). · cites it 7× “Appellant's motion to dismiss alleged that the action involved a dispute required to be arbitrated first pursuant to section 718.1255, Florida Statutes (1995).”

BACON Fam. PARTNERS v. Apollo Condo. Ass'n, Inc., 852 So. 2d 882 (Fla. 2d DCA 2003). · cites it 3× “NOTES [1] The case was not referred to mandatory nonbinding arbitration pursuant to section 718.1255, Florida Statutes (2001).”

United Grand Condo. Owners, Inc. v. Grand Condo. Ass'n, Inc., 929 So. 2d 24 (Fla. 3d DCA 2006). · cites it 7× “, the filing of a petition with the Division of Florida Land Sales, Condominiums and Mobile Homes [the Agency] for non-binding arbitration pursuant to section 718.1255, Florida Statutes (2004).”

Sterling Condo. Ass'n v. Herrera, 690 So. 2d 703 (Fla. 3d DCA 1997). · cites it 6× “In May 1996, when the case was already set for trial on Herrera's counterclaim, Herrera filed an Amended Motion for Rehearing, to Dismiss, and to Vacate Final Summary Judgment arguing that the trial court lacked subject matter jurisdiction because Sterling had failed to comply…”

Show all 50 citing cases →

— 718.1255(1) — 14 cases

Gomez v. Fradin, 41 So. 3d 1068 (Fla. 4th DCA 2010). “See § 718.1255(1), Fla. Stat. (2009). The term “dispute” does not, however, include “breaches of fiduciary duty by one or more directors.”

Carlandia Corp. v. Obernauer, 695 So. 2d 408 (Fla. 4th DCA 1997). “The question posed in this case is whether section 718.1255, Florida Statutes (Supp.”

Palisades Owners' Ass'n, Inc v. Thomas F. Browning, 247 So. 3d 589 (Fla. 1st DCA 2018). “The Association moved to dismiss the complaint, arguing that Browning was required to submit his claim to nonbinding arbitration pursuant to section 718.1255, Florida Statutes (2016), before filing suit because the disagreement between the parties was a garden-variety dispute…”

Habitat II Condo., Inc. v. Kerr, 948 So. 2d 809 (Fla. 4th DCA 2007). “In section 718.1255, Florida Statutes (2005), the Florida Legislature provided a non-binding arbitration mechanism for resolving most issues which arise between a condominium association and individual unit owners.”

Gonzalez & Leal v. Int'l Park Condo. I Assoc., Inc., 217 So. 3d 1128 (Fla. 3d DCA 2017).

— 718.1255(1)(a) — 2 cases

Summit Towers Condo. Ass'n Inc. v. Coren, 707 So. 2d 416 (Fla. 4th DCA 1998).

— 718.1255(1)(a)(2) — 1 case

Carlandia Corp. v. Obernauer, 695 So. 2d 408 (Fla. 4th DCA 1997). “The question posed in this case is whether section 718.1255, Florida Statutes (Supp.”

— 718.1255(1)(b) — 4 cases

Adanan Javan, Singer 5070, LLC, Singer 5070 2, LLC, Seawinds 20d South, LLC & Seawinds 10d South, LLC v. Seawinds South Condo. Ass'n, Inc. (Fla. 4th DCA 2021).

2944 Trivium Circle, LLC v. Trivium Park HC, LLC (Fla. 4th DCA 2025).

— 718.1255(1)(c) — 3 cases

Wing Kei Ho & Karen Yeh- Ho v. Fountains of Palm Beach Condo., Inc. 3 (Fla. 4th DCA 2020).

Bmc Southwood LLC v. Bobby Monochelli (Fla. 3d DCA 2022).

— 718.1255(3) — 4 cases

Blum v. Tamarac Fairways Ass'n, Inc., 684 So. 2d 826 (Fla. 4th DCA 1996). “Appellant's motion to dismiss alleged that the action involved a dispute required to be arbitrated first pursuant to section 718.1255, Florida Statutes (1995).”

Carlandia Corp. v. Obernauer, 695 So. 2d 408 (Fla. 4th DCA 1997). “The question posed in this case is whether section 718.1255, Florida Statutes (Supp.”

Sterling Condo. Ass'n v. Herrera, 690 So. 2d 703 (Fla. 3d DCA 1997). “In May 1996, when the case was already set for trial on Herrera's counterclaim, Herrera filed an Amended Motion for Rehearing, to Dismiss, and to Vacate Final Summary Judgment arguing that the trial court lacked subject matter jurisdiction because Sterling had failed to comply…”

Clark v. England, 715 So. 2d 365 (Fla. 5th DCA 1998).

— 718.1255(3)(b) — 2 cases

Aquarius Condo. Ass'n, Inc. v. Boris Goldberg & Carolyn Crooks (Fla. 4th DCA 2021).

Balis v. Martin (M.D. Fla. 2021).

— 718.1255(4) — 14 cases

Brindise v. U.S. Bank Nat'l Ass'n, 183 So. 3d 1215 (Fla. 2d DCA 2016). “§ 718.1255 (4), Fla. Stat. (2014). The Legislature knows how to create a condition precedent.”

Carlandia Corp. v. Obernauer, 695 So. 2d 408 (Fla. 4th DCA 1997). “The question posed in this case is whether section 718.1255, Florida Statutes (Supp.”

Beach Terrace Ass'n v. Wanda DiPaola Stephen Rinko Gen. P'ship, 27 So. 3d 147 (Fla. 2d DCA 2010).

— 718.1255(4)(a) — 18 cases

Neate v. Cypress Club Condo., Inc., 718 So. 2d 390 (Fla. 4th DCA 1998). “NOTES [1] § 718.1255 Fla. Stat. (1989). [2] The statute was later amended without substantial change to these provisions.”

Carlandia Corp. v. Obernauer, 695 So. 2d 408 (Fla. 4th DCA 1997). “The question posed in this case is whether section 718.1255, Florida Statutes (Supp.”

Clipper v. Bay Oaks Condo. Ass'n, Inc., 810 So. 2d 541 (Fla. 2d DCA 2002).

— 718.1255(4)(b)(l) — 1 case

Winding Wood Condo. VI Ass'n, Inc. v. Walls, 196 So. 3d 489 (Fla. 2d DCA 2016).

— 718.1255(4)(c) — 4 cases

Brown v. Rice, 716 So. 2d 807 (Fla. 5th DCA 1998).

Kahn v. Villas at Eagles Point Condo. Ass'n, 693 So. 2d 1029 (Fla. 2d DCA 1997).

Huff v. Vill. of Stuart Ass'n, 741 So. 2d 1217 (Fla. 2d DCA 1999).

Cypress Bend Condo. I Ass'n v. Dexner, 705 So. 2d 681 (Fla. 4th DCA 1998).

— 718.1255(4)(d) — 2 cases

Kahn v. Villas at Eagles Point Condo. Ass'n, 693 So. 2d 1029 (Fla. 2d DCA 1997).

Huff v. Vill. of Stuart Ass'n, 741 So. 2d 1217 (Fla. 2d DCA 1999).

— 718.1255(4)(e) — 1 case

Ruffin v. Kingswood E. Condo. Ass'n, 719 So. 2d 951 (Fla. 4th DCA 1998). “("Association"), brought an arbitration proceeding under section 718.1255, Florida Statutes (1995), against unit owner Mary Ruffin and her son, appellant Paul Ruffin, alleging that because of physical altercations on the Association's premises involving appellant, who the…”

— 718.1255(4)(h) — 1 case

Gallagher v. Manatee Cnty., 927 So. 2d 914 (Fla. 2d DCA 2006).

— 718.1255(4)(i) — 1 case

Beach Terrace Ass'n v. Wanda DiPaola Stephen Rinko Gen. P'ship, 27 So. 3d 147 (Fla. 2d DCA 2010).

— 718.1255(4)(k) — 10 cases

NAT. VENTURES, INC. v. Water Glades 300 Condo. Ass'n, 847 So. 2d 1070 (Fla. 4th DCA 2003). “§ 718.1255, Fla. Stat. (1995). Pursuant to the legislature's 1997 amendment of section 718.”

Nine Island Avenue Condo. Ass'n v. Siegel, 23 So. 3d 1248 (Fla. 3d DCA 2009).

Beach Terrace Ass'n v. Wanda DiPaola Stephen Rinko Gen. P'ship, 27 So. 3d 147 (Fla. 2d DCA 2010).

— 718.1255(4)(l) — 1 case

Boca View Condo. Ass'n, Inc. v. Eleanor Lepselter & Edward Lepselter (Fla. 4th DCA 2024).

— 718.1255(4)(m) — 2 cases

Boca View Condo. Ass'n, Inc. v. Eleanor Lepselter & Edward Lepselter (Fla. 4th DCA 2024).

Richard M. Samuel v. Hamptons West Condo. Ass'n Inc. (Fla. 3d DCA 2022).

— 718.1255(l)(b) — 1 case

Mitchell v. Beach Club of Hallandale Condo. Assoc. Inc., 17 So. 3d 1265 (Fla. 4th DCA 2009).

— 718.1255(l)(b)(2) — 1 case

Intracoastal Point Condo. Ass'n v. Horowitz, 54 So. 3d 528 (Fla. 3d DCA 2011).

Annotations are extracted automatically from the opinions in the Syfert caselaw corpus and ranked by authority, recency, and treatment. Dots show Syfertize treatment of the citing case itself.