## Facts

- Nachon Enterprises, Inc. recorded a construction lien against real property owned by Alexdex Corporation and filed a lien-foreclosure action in county court.
- Alexdex later filed a circuit-court complaint to show cause and to discharge the lien.
- Nachon moved to dismiss in circuit court, asserting its county-court foreclosure action had already been timely filed.
- The circuit court discharged the lien based on Nachon’s asserted failure to properly respond in the show-cause proceeding.
- The district court of appeal reversed, reinstated the lien, and held the county court could hear the foreclosure because the amount in controversy fell within county court monetary jurisdiction.
- The Florida Supreme Court accepted review to resolve conflict over whether equitable construction lien foreclosures lie exclusively in circuit court.

## Issues

1. Whether circuit courts have exclusive jurisdiction over construction lien foreclosure actions because they are equitable, or whether county courts have concurrent equity jurisdiction within their statutory monetary limits.
2. For monetary jurisdiction, whether a foreclosure action’s amount in controversy is measured by the debt secured by the lien rather than the value of the encumbered real property.
3. Whether construction lien foreclosure actions necessarily “involve the title and boundaries of real property” so as to preclude county-court jurisdiction.

## Decision

- The Florida Supreme Court approved the district court’s decision and held that circuit courts and county courts (within statutory monetary limits) have concurrent jurisdiction in equity matters.
- It concluded county courts may adjudicate construction lien foreclosure actions when the lien amount is within county court monetary jurisdiction.
- It endorsed measuring the jurisdictional amount by the debt/lien amount, not the property’s market value.
- It rejected the view that such foreclosures necessarily involve both title and boundary disputes that would bar county-court jurisdiction.
- The lien was reinstated, and the county-court foreclosure action was confirmed as properly filed.

## Legal Principles

- Florida circuit courts and county courts possess concurrent equity jurisdiction when the amount in controversy falls within county court monetary limits.
- A construction lien foreclosure may be brought in county court if the lien/debt sought to be enforced is within county court jurisdictional limits.
- In foreclosure-related jurisdictional analysis, the amount in controversy generally turns on the debt secured, not the value of the property.
- A construction lien foreclosure does not necessarily involve disputes over both title and boundaries in a manner that categorically removes it from county-court jurisdiction.

## Conclusion

The Florida Supreme Court held that county courts have limited but real equity jurisdiction and may hear construction lien foreclosure actions within their monetary limits, with jurisdiction measured by the lien debt rather than the property’s value, and it reinstated the lien discharged by the circuit court.


Alexdex Corp. v. Nachon Enters., Inc., 641 So. 2d 858 (Fla. 1994)