In RSM 18, LLC v. Executive Centre, LLC (Fla. 4th DCA Jan. 7, 2026), the Fourth District Court of Appeal reversed a landlord’s summary judgment victory in a commercial lease dispute, holding that a tenant cannot be deemed in default for failing to restore a security deposit unless the landlord strictly complies with the lease’s notice-and-demand requirements.

The dispute arose after the tenant fell behind on rent during the early months of the COVID-19 pandemic. The landlord applied the tenant’s security deposit to the delinquent rent, as permitted by the lease. The tenant later paid all outstanding rent and, months afterward, attempted to exercise a five-year lease extension option while simultaneously tendering funds to replenish the deposit.

The landlord rejected the extension, arguing the tenant remained in default because the deposit had not been restored within five days after it was applied. The trial court agreed and granted summary judgment for the landlord, effectively forfeiting the tenant’s extension rights.

The Fourth DCA reversed.

The lease did not merely require notice that the security deposit had been used. It required a request that the tenant restore the deposit. The court held that the landlord’s December 2020 email—although it declared the tenant in default and referenced the use of the security deposit—did not constitute a demand or request to replenish the deposit as required by the lease’s plain language. Without that request, the tenant could not be in default on that ground.

The court also noted that even if a later email could arguably be construed as a request, the tenant restored the deposit within five days, curing any potential breach.

The takeaway is straightforward and important: Commercial landlords must strictly follow their own lease language when declaring defaults, particularly when default status affects valuable rights such as renewal or extension options. Courts will not rewrite leases or relax express prerequisites to default, even where the tenant previously fell behind on rent.

For tenants, the case underscores the value of closely analyzing default provisions before accepting a landlord’s assertion that an option has been forfeited. For landlords, it is a reminder that precision in notices and demands matters—especially when summary judgment is sought.