I don't think so. Cars are sold all the time with no title. As long as you can show proof of ownership (bill of sale) and proof it was previously registered then he should be good to go.

I went and dug up my email I got from the DMV. This is what they said..

"Thank you for your recent inquiry.
>
> When the vehicle is a used trailer (homemade or manufactured) having a
> net weight of less than 2,000 pounds, a bill of sale and the previous
> owner's license plate number is required. If the used trailer (homemade
> or manufactured) has never been registered in Florida, a certified
> weight slip is also required. A title is not required for any trailer
> having a net weight of less than 2,000 pounds.
>
>
> However, a copy of the MCO and/or a bill of sale is required. You can
> process the registration transaction at a Florida tax collector's
> office. >
>
> We hope this information will assist you.
>
> 07/08/09 "

-Mark