865 East 49th Street Associates LLC v. Valdo Auto Sales Corp.: Florida Appeals Court Upholds Zero-Dollar Fraud Award for Commercial Landlord Already Paid Back Rent
On October 7, 2026, Florida's Third District Court of Appeal affirmed a Miami-Dade circuit court ruling in a commercial landlord's suit against its tenant, Valdo Auto Sales Corp. The landlord, 865 East 49th Street Associates LLC, had won liability on all of its claims, including fraud and unjust enrichment. But the trial court awarded only $76,199.37 in past-due rent for breach of the commercial lease and nothing on the other claims. The appeals court held that the landlord never showed any damages on the fraud and unjust enrichment claims that were separate from the rent award, so a zero award on those claims stands.
Why it matters
Landlords often add fraud and unjust enrichment counts to a lease suit to get more leverage or more money. This ruling says winning liability on those counts is worth nothing unless the landlord proves a measurable loss that the contract award does not already cover. It also shows how an appeal can fail on the record alone: the landlord did not transcribe the hearings where liability and damages were decided, and the court would not assume the agreed judgment preserved anything it did not say.
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Case timeline · 1 entry Latest: October 7, 2026 — Third DCA affirms summary judgment awarding $76,199.37 in back rent and zero on fraud and unjust enrichment
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