From Florida Legal Wiki
In order to establish an action for civil theft, the claimant must prove the statutory elements of theft, as well as criminal intent. See § 772.11, Fla. Stat.; Country Manors Ass'n v. Master Antenna Sys., Inc., 534 So.2d 1187, 1191 (Fla. 4th DCA 1988).
Where the property at issue is also the subject of a contract between the parties, a civil theft claim requires additional proof of “an intricate sophisticated scheme of deceit and theft.” Trend Setter Villas of Deer Creek v. Villas on Green, 569 So.2d 766, 767 (Fla. 4th DCA 1990).
Gersh v. Cofman, 769 So.2d 407, 409 (Fla. 4th DCA 2000).