A Circuit Judge in Orlando, Florida, dismissed an action for a deficiency judgment, with prejudice, filed by Dyck O’Neal. The defendant resided in California and purchased property in Florida for personal use. Falling on hard times, the defendant was unable to make the mortgage payments and a foreclosure judgement was entered against him and the property was sold at auction. Thereafter, 6 years later, Dyck O’Neal filed the action for a deficiency judgment seeking $203,000. In its order, the Court reasoned that the while the defendant, at one time, had minimum contacts with the State of Florida by owning real estate sufficient to subject him to Florida Courts, he no longer owned the property after the original foreclosure action. Dyck O’Neal v. Larry Rojas, Case No. 2014-CA-1369.