A 2000 mobile home affixed to the land sits at the center of the tangle
A Florida appeals court has voided a certificate of title from a foreclosure sale after knocking out the judgment behind it.
On August 14, 2026, the Fifth District Court of Appeal reversed a trial court order in favor of Carrington Mortgage Services - yet the ruling still sends the servicer back to square one, with the title from a completed foreclosure sale now stripped of legal effect.
The dispute traces to a 2014 foreclosure in Hernando County. Carrington foreclosed, the property sold at a judicial sale, and a certificate of title - the paper confirming ownership passed to the buyer - was issued.
Carrington then returned to the trial court with a request: add details about a mobile home to the summary final judgment and to the title. The home, a 2000 model, sat affixed to the land and, as the court put it, "running with the secured land" - part of the collateral securing the loan. The trial judge refused. Carrington appealed.
That appeal traveled alongside another. In a companion case, the same court had already reversed the underlying foreclosure judgment and sent it back for more proceedings. That fight centered on Carrington's push to correct the property's legal description with a sharper "metes and bounds" boundary, the surveyor's way of mapping land by precise distances and directions. Both appeals sprang from a single summary final judgment.
When that judgment fell, the rest went with it. The panel was direct: with the final judgment reversed, the certificate of title issued after the sale "is no longer of any legal force or effect." A void title left nothing for the appealed order to stand on.
So the court reversed the trial judge's denial and remanded the matter - back to the trial court to be sorted out again. The panel also called Carrington's appeal "otherwise meritorious," a nod that the servicer's mobile-home argument carried weight, even though the reversal rested on the collapsed title.
The practical signal for servicers sits in the property description. This appeal existed because the collateral was never pinned down cleanly - first the boundary, then a mobile home bolted to the land. Loose descriptions force fixes after the sale, and a reversal upstream can wipe out whatever the sale produced.
The opinion came per curiam, unsigned and issued by the panel together. It is not yet final: under Florida's appellate rules, it stays open until the court disposes of any timely motion for rehearing.
