Carrington Mortgage Services v. Tessenear — Reversed denial of request to add mobile-home information to foreclosure documents

Case
Carrington Mortgage Services, LLC v. Michael Tessenear, Cary L. Tessenear, and Steven K. Jonas, as Trustee of the 4785 Oakfield Circle Trust, Dated, February 28, 2006
Court
Florida Fifth District Court of Appeal
Judge
JAY, C.J. (Ron DeSantis, 2023); SOUD, J. (appointment info not available); BOATWRIGHT, J. (Ron DeSantis, 2022)
Date Decided
August 14, 2026
Docket No.
5D2025-2502
Topics
Foreclosure; Certificate of title; Mobile homes; Property description
Source
Read the full opinion

Background

Carrington Mortgage Services, LLC appealed an order denying its motion to add information about a 2000 mobile home to a summary final judgment of foreclosure and the certificate of title issued after the judicial sale of the property.

The mobile home was affixed to the land and, according to Carrington, ran with the secured property. The appeal arose from the same summary final judgment involved in a companion case, 5D2025-1687, concerning Carrington’s claim to reform the property’s legal description with a more precise metes-and-bounds description.

The Court’s Holding

The Fifth District reversed. In the companion appeal, the court had reversed the underlying final judgment of foreclosure and remanded for further proceedings.

Because that final judgment had been reversed, the certificate of title issued following the foreclosure sale was no longer legally effective. The court therefore reversed the order denying Carrington’s motion to add the mobile-home information and remanded for further proceedings consistent with its opinion.

Key Takeaways

  • Reversal of the underlying foreclosure judgment eliminated the legal force of the resulting certificate of title.
  • The appellate court reversed the denial of Carrington’s request to add the affixed mobile home to the property description.
  • The case returns to the trial court for further proceedings following reversal of the foreclosure judgment.

Why It Matters

The decision illustrates that orders and title documents dependent on a foreclosure judgment may not stand once that judgment is reversed. It also preserves Carrington’s ability to seek appropriate treatment of the mobile home and property description on remand.

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