Curbstoning Laws in Florida: Penalties, Warning Signs & Buyer Rights

Curbstoning is the practice of selling multiple vehicles as a private seller while actually operating as an unlicensed dealer. In Florida, this activity is illegal and carries criminal and civil penalties. Buyers who unknowingly purchase from curbstoners often end up with undisclosed damage, bad titles, or no legal recourse.

Florida Curbstoning at a Glance

Penalty: 2nd degree misdemeanor; $500–$2,500 fine per violation (FL Stat. §320.27)
Dealer Threshold: 3+ vehicles sold per year presumed dealer (FL Stat. §320.27(1))
Consumer Remedy: FL DHSMV complaint + FL AG Consumer Protection
Report To: Florida DHSMV Division of Motorist Services

What Counts as Curbstoning in Florida?

Dealer threshold: 3+ vehicles sold per year presumed dealer (FL Stat. §320.27(1))

FL defines "motor vehicle dealer" as anyone who sells 3 or more motor vehicles in a 12-month period. Selling 2 vehicles is generally permissible for private individuals, but the third sale triggers the dealer licensing requirement.

Penalties for Curbstoning in Florida

2nd degree misdemeanor; $500–$2,500 fine per violation (FL Stat. §320.27)

FL §320.27 prohibits acting as a dealer without a license. Each vehicle sold constitutes a separate violation, each carrying a $500–$2,500 fine. DHSMV may also impose license plate and registration holds on the vehicles involved.

Warning Signs: Spotting a Florida Curbstoner

⚠Seller lists 3+ vehicles in the same week on Facebook Marketplace or Craigslist (FL)
⚠No valid FL registration transfer paperwork — curbstoners often skip title due diligence
⚠Vehicle was recently titled in a neighboring state (GA, AL) — possible title laundering
⚠No FL safety inspection (not required statewide but note absence of any recent maintenance records)
⚠Price is suspiciously below NADA/KBB for the vehicle condition

Risks of Buying from a Curbstoner in Florida

✗FL private sales are as-is under §672.316 — no implied warranty of merchantability
✗FL title fraud is common; curbstoners source flood-damaged vehicles from hurricane states
✗Buyer may receive a title with undisclosed liens from the curbstoner's auction financing
✗DHSMV investigation can freeze title transfer for weeks if fraud is reported post-sale
✗Curbstoner may not provide proper odometer disclosure, creating federal MVISA liability

Your Rights as a Buyer in Florida

Remedy available: FL DHSMV complaint + FL AG Consumer Protection

FL buyers defrauded by curbstoners can file with the FL AG under FL's Unfair and Deceptive Trade Practices Act (FDUTPA), which allows recovery of actual damages plus attorney fees.

How to Report Curbstoning in Florida

Agency: Florida DHSMV Division of Motorist Services

File online at flhsmv.gov or call (850) 617-2000. Include VIN, photos of ads, and seller contact information.

Florida-Specific Note

FL's 3-vehicle threshold is low. With FL's large inventory of auction-sourced hurricane damage vehicles, curbstoners here often specialize in "flood title washing" — buying cheap, reregistering in GA or AL, then selling in FL as clean-title vehicles.

Frequently Asked Questions

What is curbstoning and is it illegal in Florida?

Curbstoning — selling cars repeatedly without a dealer license — is illegal in Florida. FL §320.27 prohibits acting as a dealer without a license. Each vehicle sold constitutes a separate violation, each carrying a $500–$2,500 fine. DHSMV may also impose license plate and registration holds on the vehicles involved.

How many cars can you sell per year in Florida without a dealer license?

3+ vehicles sold per year presumed dealer (FL Stat. §320.27(1)). FL defines "motor vehicle dealer" as anyone who sells 3 or more motor vehicles in a 12-month period. Selling 2 vehicles is generally permissible for private individuals, but the third sale triggers the dealer licensing requirement.

What can I do if I was defrauded by a curbstoner in Florida?

FL DHSMV complaint + FL AG Consumer Protection. FL buyers defrauded by curbstoners can file with the FL AG under FL's Unfair and Deceptive Trade Practices Act (FDUTPA), which allows recovery of actual damages plus attorney fees.

How do I report an illegal dealer in Florida?