In short: Recent decisions keep coming out the same way: an owner who doesn’t appeal a code enforcement order within 30 days is generally bound by it. In November 2025 the Fourth District reinstated $676,650 in liens that a trial judge had cut to about $94,000. Excessive-fine challenges raised late have failed in state and federal court.
Matt Weidner has argued for years that Florida taxpayers are owed large sums in unpaid code fines. Three recent cases explain why those liens hold up in court.
City of Lauderdale Lakes v. Allen (Fla. 4th DCA 2025)
A special magistrate imposed five daily fines between 2019 and 2021, totaling $676,650. The city recorded the liens and sued to foreclose. The trial judge raised constitutional objections on his own and recalculated the liens to $93,903.28. On November 12, 2025, the Fourth District reversed (No. 4D2024-2584). The court held the trial judge exceeded his jurisdiction: a party unhappy with a special magistrate’s order can appeal it or be bound by it. The full amounts were reinstated, with interest and costs to be calculated on remand.
DJB Rentals, LLC v. City of Largo (Fla. 2d DCA 2023)
The owner challenged Largo’s fines after the fact. The Second District held the challenge came too late under the 30-day appeal window in Chapter 162 (373 So. 3d 405). The owner then filed a federal suit in May 2025 arguing the fines are constitutionally excessive and that he lost the property without due process. In October 2025 the federal court denied the city’s motion to dismiss. That case is pending, and it is the one to watch.
Innova Investment Group v. Village of Key Biscayne (11th Cir. 2024)
In an unpublished 2024 decision, the Eleventh Circuit affirmed dismissal of an excessive-fines challenge. The federal claim was time-barred, and the state claim failed because the owner never appealed the fine to circuit court within 30 days.
What These Cases Mean
- For cities: properly noticed and recorded fine orders are enforceable, and courts will not let a trial judge rewrite them in a foreclosure.
- For owners: the 30-day appeal under § 162.11 is the moment to fight. After that, arguments that fines are excessive face procedural bars.
- The open question: Since Timbs v. Indiana (2019), the Excessive Fines Clause applies to the states. Whether a timely challenge can cap very large daily fines is the issue in the pending Largo federal case.
Defunct Corporations Still Owe
Many of the largest liens sit on property owned by administratively dissolved LLCs and corporations. Dissolution doesn’t erase the lien or the property. Proper service on a dissolved entity and its registered agent or officers lets the case proceed.
Watch: the videos behind this article
Florida Taxpayers are owed BILLIONS of dollars — and it’s not being collected. Here's how.
Florida Taxpayers Are Owed BILLIONS — Here’s How to Collect It
STATE OF FLORIDA: THIS IS THE SOLUTION TO COLLECTING BILLIONS OF DOLLARS
More Short Videos on This Issue
Watch the Real Appellate Arguments
This is a recording of an actual appellate argument over a city’s code liens wiped out at a later sale, posted on the channel. An argument is not a ruling: read the written opinion before relying on any outcome.
Code Liens Wiped, House Resold for More — Can the City of Miami Claim Sovereign Immunity?
Go Deeper
Frequently Asked Questions
What happened in City of Lauderdale Lakes v. Allen?
The Fourth District reversed a trial judge who had cut $676,650 in code liens to about $94,000, holding that an owner who doesn’t appeal a special magistrate’s order is bound by it.
Can I challenge a code enforcement fine as excessive in Florida?
Raise it promptly, through the 30-day appeal under § 162.11. Late challenges have been rejected in state and federal court.
Is the DJB Rentals v. Largo case over?
The state case ended in 2023 against the owner. A federal excessive-fines suit filed in 2025 survived a motion to dismiss and is pending.
Does dissolving an LLC erase a code enforcement lien?
No. The lien stays on the property, and a dissolved entity can still be served and its property foreclosed.
Talk to a Florida code enforcement lawyer
Weidner Law, P.A. represents Florida cities and counties in code enforcement lien foreclosure and lien clearing, and advises property owners facing code liens. To talk about a program or a specific property, call (727) 954-8752 or email weidner@mattweidnerlaw.com.
Read the law yourself, free: every Florida rule and statute is on floridarules.net.
This article is general information about Florida law, not legal advice about your situation. Reading it, watching the videos, or contacting the firm does not create an attorney-client relationship. Every case turns on its own facts, and past results do not guarantee a similar outcome. The hiring of a lawyer is an important decision that should not be based solely upon advertisements.
