5D2025-0160 — Gregory Lattimer, Appellant, v. Eric Babcock, Appellee. (2026)

The Fifth District Court of Appeal reversed a trial court's grant of summary judgment in a defamation case brought by an HOA board member against a neighbor who made statements at an HOA meeting.

The court held that summary judgment was improper because material factual disputes exist regarding whether the defendant acted negligently in making defamatory statements. The defendant claimed he learned of a shooting threat and hate crime investigation from unnamed law enforcement and code enforcement officers, but could not identify those officers, provide corroborating evidence, or recall details about them. The court found these credibility and verification issues must be resolved by a jury, not decided on summary judgment, particularly where the defendant made inconsistent statements about the source of his information.

Homeowners' association members and residents involved in disputes or defamation claims arising from statements made at HOA meetings.

Decision issued May 1, 2026; no new effective date for statutory rules—this is a judicial interpretation of existing defamation law.