Florida real estate agent and flat-fee broker Jorge A. Zea has filed a lawsuit against the National Association of Realtors® (NAR), along with other local associations and MLSs, for alleged antitrust violations and steering.
In his filing, Zea claims that the defendants’ “coordinated scheme” targeted his pro-competitive brokerage model, restricted consumer choice and maintained supracompetitive prices. His brokerage, Snap Flat Fee, is designed to charge sellers a low listing fee in exchange for limited brokerage services.
In the 126-page Pro Se filing, Zea claims that, “While the narrative may be lengthy, given the number of defendants and the multiple rules and actions at issue, the injunctive relief sought is, by contrast, straightforward and indisputable: that defendants comply with, monitor and enforce the same pro-competitive rules they impose on themselves.”
Snap Flat Fee syndicates listing data to the MLS-enabled data feed, and Zea forwards all leads, “regardless of their origin,” directly to the seller. For that transparency to occur, there can not be any “unnecessary steering, misleading, misrepresentation, interference, diversion, deflection, funneling or redirection,” according to the filing.
An NAR spokesperson told RISMedia that “(t)he National Association of Realtors® fosters a fair, transparent, and competitive real estate marketplace. 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 MLS rules are enforced at the MLS level. We will respond to the plaintiff’s claims in court.”
Zea previously sought to intervene in the Burnett settlement, putting forth many of the same allegations and claiming that an anti-steering stipulation proposed as part of the deal was modified. NAR previously claimed that the terms of the settlement prevented “theoretical steering” related to buyer agent commissions.
In his lawsuit, Zea claims the listed defendants “directly obstruct(ed) that flow of contact information, intentionally frustrating the essential function” of his service and caused substantial, ongoing harm.
“Defendants’ coordinated failures and actions have denied plaintiff the opportunity to grow, scale, gain market share, increase revenue, profit, build brand recognition, increase business value and compete fairly, ultimately foreclosing Plaintiff’s ability to establish a leading, cost-saving alternative in the national real estate market,” read the filing.
Alleged Steering
In the filing, Zea accuses the defendants of having buyer agents steer clients away from properties that offer reduced or no buyer-agent commissions, by filtering them out, omitting them from recommendations or actively disparaging them. By keeping buyers removed from direct contact with sellers or listing agents representing alternative models, these defendants are “steering them towards buyer agent representation,” Zea argues.
According to the filing, online platforms routinely obscure or omit the listing agent’s contact information, “further distancing buyers from the seller and reinforcing the steering dynamic.”
Between September 2024 and January 2025, Zea—allegedly confronted with multiple issues of steering—filed at least one ethics complaint with each of the “ethics-responsible” defendants and all cases were dismissed.
‘Selective Enforcement’
In the filing, Zea also outlines what he refers to as “selective enforcement” by the defendants when it comes to “enforcing authority against rules protecting historic commission structures.”
The defendants, argues Zea in the court document, enacted a “coordinated suppression of innovation, alternative business models, transparency, consumer choice and price competition by design.”
Filed in the U.S. District Court for the Southern District of Florida’s West Palm Beach Division, Zea is suing the following groups:
- NAR
- Beaches MLS
- Broward, Palm Beaches & St. Lucie Realtors®
- Miami Association of Realtors®
- Orlando Regional Realtor® Association (ORRA)
- Florida Gulf Coast Multiple Listing Service
- Royal Palm Coast Realtor® Association
- Naples Area Board of Realtors® and Association of Real Estate Professionals (NABOR®)
- Stellar MLS
- Space Coast Multiple Listing Service and Space Coast Association of Realtors®
- RealMLS
- Northeast Florida Association of Realtors®
- Central Panhandle Association of Realtors®
- Connecticut Association of Realtors®
- Smart MLS
- West and Southeast Realtors® of the Valley (WeSERV)
- Midwest Real Estate Data