What Puleo v. Cohen means for every Florida property owner who has ever taken a buyer at their word.
Picture this. You have spent years building equity in a property you care about. When the time comes to sell, you receive multiple offers, including some that are considerably higher than the one you ultimately accept. You take the lower number because the buyer tells you something that matters to you: that she and her family plan to make it their home. Maybe it is the house where you raised your children, or a beach residence you poured money and attention into over the years. The buyer's intention feels like part of the deal. So you agree. You sell.
Two months later, the property is back on the market. The buyer who was supposed to be moving in is nowhere to be found. The real purchaser, a developer whose name you had never heard until two days before closing, has listed your former home at nearly twenty million dollars. You sold it for thirteen.
That is not a hypothetical. That is the story behind Puleo v. Cohen, a Florida appellate decision issued on March 11, 2026, and it should get the attention of anyone who has ever sold a piece of real estate in this state.
What Happened
Marc Puleo sold his Miami Beach residence for $13 million to a buyer he understood to be Maria Drummond, a woman who, by all representations made to him, intended to live in the property with her family. He turned away higher offers. He agreed to sell the house fully furnished. The deal, from his perspective, was shaped by who he believed was sitting across the table.
In reality, the entire transaction had been engineered by Edmund Irvine, a sophisticated real estate developer and Drummond's domestic partner. Irvine forged Drummond's name on the purchase contract. He had no intention of living anywhere near the property. His plan, from the first day, was to tear the house down and flip the land for a profit. Shortly before closing, he formed a limited liability company called Spanish Rose, forged Drummond's signature again on an assignment of the purchase rights to that entity, and proceeded to close the deal. Puleo received a draft closing statement identifying Irvine as the authorized member of Spanish Rose two days before closing. By that point, walking away would have exposed Puleo to a specific performance lawsuit and a fee claim. He closed.
Within two months, Spanish Rose relisted the property. It sold within the year for nearly sixteen million dollars. Puleo, who had turned away substantially higher offers in the belief that a family was buying his home to live in it, had been used.
The Courthouse Fight
Puleo sued. His claims targeted Irvine, the real estate brokers who facilitated the transaction, and the closing and escrow agents. The central theory was that the parties had conspired to conceal both the buyer's true identity and his actual intentions, inducing Puleo to sell below his asking price. He sought approximately $4.5 million in damages.
The trial court granted summary judgment against him across the board on the fraud and conspiracy claims. The court found evidence of misrepresentation but concluded that Puleo had not adequately shown what the law calls justifiable reliance: in essence, that he had a good enough reason to trust what he was told. Because the fraud claim failed, the court reasoned, the conspiracy claim had to go as well. Puleo appealed.
The Third District Court of Appeal reversed. Its opinion is a significant one, and not only for Puleo.
The Legal Principle That Could Protect You
Here is the part that matters most for Florida property owners and sellers.
The trial court had asked whether Puleo was justified in believing what the buyer told him. That sounds reasonable until you understand what that standard actually requires. Under a justifiable reliance framework, a defrauded seller can be held partly responsible for the fraud against him, on the theory that a more careful investigation would have uncovered the deception. In practical terms, it shifts a portion of the blame from the liar to the person who believed the lie.
The Florida Supreme Court rejected that approach years ago in a case called Butler v. Yusem, and the Third District held that the trial court should have followed it here. Florida law requires only reliance, not justifiable reliance, to maintain a fraud claim. The policy behind that rule is simple and worth stating plainly: a person who deliberately uses false information to induce another into a transaction should not be allowed to benefit from his own deception by pointing to the victim's failure to catch him. The wrongdoer bears the risk of his wrongdoing.
For Puleo, that meant he was entitled to take the buyer's representations at face value. He had no legal obligation to dig behind the scenes and root out the identity of the real purchaser or investigate whether someone might be forging signatures on assignments. By the time he had any reason to question the arrangement, his contractual options had effectively closed. A jury, the court held, could reasonably find that he relied on the misrepresentations and was injured as a result.
One Settlement Does Not End the Fight
The opinion also resolved an issue that comes up frequently when fraud involves multiple actors. Puleo ultimately settled with the real estate brokers during the litigation and voluntarily dismissed his claims against them. The remaining defendants argued that the settlement extinguished the conspiracy claim against everyone, on the theory that you cannot have a conspiracy without a co-conspirator who is still in the case.
The Third District rejected that argument as well. Under Florida law, a co-conspirator's liability does not depend on whether every other participant in the scheme remains a named defendant. A conspirator need only know of the scheme and assist in it to be held responsible for what the others did. Parties who were not part of a settlement agreement cannot invoke its protections. A release discharges the claims it was meant to discharge, and nothing more. The defendants who did not settle received no benefit from the one who did.
That matters in any fraud case involving a chain of professionals, intermediaries, or transaction participants. A plaintiff who reaches a partial resolution with one defendant should not be forced to forfeit the entire case as the price of that settlement.
What This Means If You Have Been There
Real estate fraud is not always a stranger in a dark alley. It is often dressed in a purchase contract, a closing table, and a handshake. It is a buyer who tells you she wants to raise her children in your home. It is a developer who decides that forging a domestic partner's signature is a reasonable way to acquire a $13 million property at a discount. It is a transaction that looks, from the outside, entirely normal until the for-sale sign goes back up two months later at a fifteen percent markup.
The law that the Third District reaffirmed in this case is meant precisely for those situations. If you sold a property in Florida and later discovered that the buyer misrepresented who he was, what he intended to do with the property, or both, you may have recourse that a trial court's dismissal of your claims does not extinguish. The appellate courts in this state have made clear that fraud victims are not required to have been perfect in order to be heard.
The outcome on remand remains to be seen. There will be a fight over damages, over the competing appraisal evidence, and over what a jury makes of the full story. But the threshold question, whether this seller's claims were legally viable and belonged before a jury, has now been answered in his favor. That answer took four years and an appeal to obtain. It should not have been necessary.
If you believe you have been on the wrong end of a transaction like this one, the time to act is not after the statute of limitations runs. Florida's fraud claims carry a four-year limitations period, and the clock does not wait for the full picture to emerge. The sooner you understand your options, the better positioned you are to protect them.
Rosenthal Law Group represents clients in commercial litigation, real estate disputes, and appellate matters throughout Florida. This commentary is for informational purposes only and does not constitute legal advice. If you believe you have been defrauded in a real estate transaction, contact our office at 954-384-9200 or www.rosenthalcounsel.com to discuss your options.