Florida Appellate Court's Comma Interpretation in Venue Dispute Draws Criticism
The Florida District Court of Appeal recently issued a decision in the case of *Treasure Coast Classical Academy, Inc. v. Optima Foundation, Inc.*, where the interpretation of a comma played a decisive role in determining whether a contract's venue provision was mandatory or permissive. The court ruled that the presence of a comma before the venue clause meant that the mandatory effect of the word 'shall' applied only to the choice of Florida law, not to the venue selection. This interpretation led the appellate court to reverse a lower court's decision, which had dismissed the complaint for improper venue, and remand the case for further proceedings. The appellate court cited previous Florida District Court of Appeal decisions, *Regal Kitchens, Inc. v. O'Connor & Taylor Condominium Construction, Inc.* and *Global Commercial Roofing, LLC v. iCrete, LLC*, to support its reasoning regarding the comma's significance in contractual language.