Judge recommends dropping CT Realtors, Smart MLS, WeSERV from Zea suit

By BrokerOwner.net February 24, 2026 Housing News

A
magistrate
judge
in
U.S.
District
Court
in
West
Palm
Beach,
Fla.,
is
recommending
that
the
court
dismiss
Connecticut-based

Connecticut
Association
of
Realtors
(CT
Realtors)
and

Smart
MLS,
as
well
as
Arizona-based

West
and
Southeast
Realtors
of
the
Valley
(WeSERV)
from
the
Zea
lawsuit.

Filed
in
August,
the
lawsuit
claims
that
the
defendants
engaged
in
a
“coordinated
scheme”
to
restrict
consumer
choice
and
maintain
elevated
prices,
harming
his

brokerage
model.

Plaintiff
Jorge
Zea
runs

www.snapflatfee.com,
a
brokerage
that
charges
sellers
a
listing
fee
in
exchange
for
limited
services.
Zea’s
firm
syndicates
listings
data
to
the
MLS
data
feeds
and
forwards
all
buyer
leads
“regardless
of
their
origin”
directly
to
the
seller.
According
to
Zea,
buyer’s
agents
associated
with
the
defendants

steer
clients
away
from
properties
that
offer
a
reduced
or
non-existent
buyer’s
agent
commission.
In
his
complaint,
he
argues
that
this
steering
is
the
result
of
the

National
Association
of
Realtors
(NAR)
and
the
other
defendants
not
enforcing
their
own
rules.

The
rules
in
question
relate
to
the
mandatory
display
of
a
listing
broker’s
contact
information
on
the
listing
page
in
an
IDX
display,
the
commission
lawsuit
mandate
for

buyer
agency
agreements
and
the
prohibition
of
MLS
platforms
from
allowing
users
to
search
or
filter
search
results
by
the
name
of
the
listing
broker
or
agent,
or
by
the
amount
of
compensation
offered.
By
allegedly
refusing
to
enforce
these
rules,
Zea
claims
that
the

defendants
have
competitively
disadvantaged
his
discount-brokerage
business.

In
his
report
and
recommendation
filed
on
Friday,
Magistrate
Judge
William
Matthewman
found
that
the
arguments
and
facts
presented
by
both
parties
in
their
filings,
that
there
is
no
personal
jurisdiction
over
the
defendants.

“The
Complaint
does
not
allege
that
Defendants,
specifically
and
as
opposed
to
other
defendants
in
this
case,
conduct
practical,
everyday
business
or
do
business
or
carry
on
business
of
any
substantial
character
in
Florida,”
the
report
states.

The
three
defendants
filed
their
motion
to
dismiss
for
lack
of
personal
jurisdiction
in
early
October
2025.

Despite
not
being
based
in
Florida,
Zea
is
arguing
that
the
actions
of
these
defendants
harmed
him,
a
Florida
resident,
and
therefore
the
court
in
Florida
should
have
jurisdiction
over
the
matter.
Additionally,
the
lawsuit
does
list
several
Florida-based
entities
as
defendants,
including

Beaches
MLS;

Broward,
Palm
Beaches
&
St.
Lucie
Realtors;

Miami
Realtors;

Orlando
Regional
Realtor
Association;

Florida
Gulf
Coast
MLS;

Stellar
MLS;

Space
Coast
MLS
and

Space
Coast
Association
of
Realtors;
RealMLS;

Northeast
Florida
Association
of
Realtors
and

Central
Panhandle
Association
of
Realtors.

In
his
report,
the
judge
found
that
the
three
defendants
do
not
operate
or
conduct
business
in
Florida
and
that
the
ethics
complaints
and
MLS
issues
cited
in
the
complaint
happened
in
Connecticut,
meaning
that
any
alleged
injury
related
to
these
defendants
occurred
from
his
business
activities
in
Connecticut,
not
from
conduct
in
Florida.

Additionally,
the
judge
reported
that
the
defendants
did
not
purposefully
direct
conduct
at
Florida
and
that
Zea
voluntarily
joined
CT
Realtors
and
Smart
MLS
and
voluntarily
did
business
in
Connecticut.

Objections
to
the
judge’s
report
are
due
by
next
Thursday.

A
previous
report
written
by
this
judge
denied
Zea’s
motion
for
a
preliminary
injunction
asking
the
court
to
compel
the
Realtor
association
and
MLS
defendants
to
enforce
their
own
rules,
was
adopted
and
approved
by
Judge
William
Dimitrouleas,
who
is
overseeing
the
lawsuit,
in
late-January
2026.

In
an
emailed
statement,
a
NAR
spokesperson
said
the
association
will
not
comment
on
the
report
until
a
final
decision
is
rendered.

“As
we
have
previously
stated,
the
National
Association
of
Realtors
fosters
a
fair,
transparent,
and
competitive
real
estate
marketplace,”
the
spokesperson
wrote.
“Steering
is
a
prohibited
practice
under
NAR
policy
and
the
Realtor
Code
of
Ethics.
The
Code
of
Ethics
is
enforced
by
state
and
local
Realtor
associations,
and
the
enforcement
of
MLS
rules
are
handled
by
each
MLS.
NAR
has filed
a
motion
to
dismiss
this
case and
agrees
with
the
court’s
decision
to
deny
Plaintiff’s
request
for
a preliminary
injunction.”