Lance v. Wade

In Lance v. Wade, 457 So. 2d 1008 (Fla. 1984), the Supreme Court held that fraud on individual contracts for the purchase of home lots could not be the basis for class action. Lance involved the purchasers of mobile home lots who claimed that they relied to their detriment upon fraudulent representations contained in the seller's public offering statement, advertising brochures, contracts for deed, as well as fraudulent representations made by the seller's employees. The Lance court made it clear that statements in Osceola Groves and Avila South still applied. The court reasoned that class action treatment was inappropriate because "what one purchaser may rely upon in entering into a contract may not be material to another purchaser." Lance, 457 So. 2d at 1011.