Judge Recommends Dropping Ct Realtors, Smart Mls, Weserv From Zea Suit

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.”

CT Realtors said it does not comment on pending litigation and none of the parties immediately returned HousingWire’s request for comment.