How cited: Lance Koster v. Carol Sullivan · Go Syfert

Lance Koster v. Carol Sullivan (2015)

green · 67 citation events across 4 courts. Showing the 28 strongest citers on record (one row per citing case, strongest signal kept).
All Green 28
Treatment trajectory · 2015 → 2026 · click a year to view the case as of then
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green East Coast Recovery, Inc. v. Patricia Holmes, A/K/A Patricia Hevia (2025)
Rule Authority · Fla. Dist. Ct. App. · 2 citations in this opinion
“The return of service is the instrument a court relies on to determine whether jurisdiction over an individual has been established.” Koster v. Sullivan, 160 So. 3d 385, 388 (Fla. 2015).
green Lloyd Newman Dubuc v. State of Florida (2025)
Rule Authority · Fla. Dist. Ct. App. · 2 citations in this opinion
Koster v. Sullivan, 160 So. 3d 385, 390 (Fla. 2015); Pepper v. Pepper, 66 So. 2d 280, 284 (Fla. 1953).
green Johnny M. Brown, Jr. v. State (2017)
Quote Authority · Fla. Dist. Ct. App. · signal: see · 2 citations in this opinion
See Roster v. Sullivan, 160 So.3d 385, 390 (Fla. 2015) (“Florida courts are ‘without power to construe an unambiguous statute in a way which would extend, modify, or limit, its express terms or its reasonable and obvious implications.
“Florida courts are ‘without power to construe an unambiguous statute in a way which would extend, modify, or limit, its express terms or its reasonable and obvious implications. To do so would be an abrogation of legislative power.’”
green James Matthews and Roberta Matthews v. U.S. Bank, National Association, etc. (2016)
Rule Authority · Fla. Dist. Ct. App. · 2 citations in this opinion
“The return of service is .the instrument a court relies on to determine whether jurisdiction over an individual has been established.” Koster v. Sullivan, 160 So.3d 385, 388 (Fla.2015), cert. denied, — U.S. -, 136 S.Ct. 164 , 193 L.Ed.2d 45 (2015).
green Sidney Norvil, Jr. v. State of Florida (2016)
Quote Authority · Fla. · signal: see · 2 citations in this opinion
See Koster v. Sullivan, 160 So. 3d 385, 390 (Fla. 2015) (“Florida courts are ‘without power to construe an unambiguous statute in a way which would extend, modify, or limit, its express terms or its reasonable and obvious implications.
“Florida courts are ‘without power to construe an unambiguous statute in a way which would extend, modify, or limit, its express terms or its reasonable and obvious implications. To do so would be an abrogation of legislative power.’ ”
green NetApp Inc. v. Jon Thorgrimur Stefánsson (2026)
Rule Authority · M.D. Fla.
In any case, when jurisdiction turns on the defendant having been personally served while present in this state, “[t]he return of service is the instrument a court relies on to determine whether jurisdiction over an individual has been established.” Koster v. Sullivan, 160 So. 3d 385, 388 (Fla. 2015); accord Murphy v. Cach, LLC, 230 So. 3d 599, 600 (Fla. Dist.
green Esther Kassin v. 3909 Ponce De Leon LLC (2025)
Quote Authority · Fla. Dist. Ct. App.
Id. at 389 (“A return of service 2 that is [facially valid] must include the statutory factors contained in section 48.21[(1)].”).
“A return of service 2 that is [facially valid] must include the statutory factors contained in section 48.21[(1)].”
green KMG PROPERTIES, LLC v. OWL CONSTRUCTION, LLC (2024)
Rule Authority · Fla. Dist. Ct. App.
After all, "[t]he return of service is the instrument a court relies on to determine whether jurisdiction over an individual has been established." Koster v. Sullivan, 160 So. 3d 385, 388 (Fla. 2015).
green TIMOTHY GIBSON v. STAR COLLISION AND TOWING, LLC (2024)
Rule Authority · Fla. Dist. Ct. App.
"The return of service is the instrument a court relies on to determine whether jurisdiction over an individual has been established." Koster v. Sullivan, 160 So. 3d 385, 388 (Fla. 2015).
green SERVIQUIM CA, etc. v. MANUCHAR NV, etc. (2023)
Rule Authority · Fla. Dist. Ct. App.
See Burnham v. Superior Ct. of California, Cnty. of Marin, 495 U.S. 604, 619 (1990) (“[J]urisdiction based on physical presence alone constitutes due process because it is one of the continuing traditions of our legal system that define the due process standard of ‘traditional notions of fair play and substantial justice.’”); Durkee v. Durkee, 906 So. 2d 1176, 1177 (Fla. 4th DCA 2005) (quoting Garrett v. Garrett, 668 So. 2d 991, 994 (Fla. 1996) (Wells, J., concurring)) (“Flo…
quoting Re-Employment Services, Ltd. v. Nat’l Loan Acquisitions Co., 969 So. 2d 467, 471 (Fla. 5th DCA 2007)
green Pinnacle Foods of California, LLC v. Popeyes Louisiana Kitchen, Inc. (2022)
Rule Authority · S.D. Fla.
Under Florida law, the return of service shall note “(1) the date and time that the pleading comes to hand or is received by the process server, (2) the date and time that process is served, (3) the manner of service, and (4) the name of the person served and, if the person is served in a representative capacity, the position occupied by the person.” Koster v. Sullivan, 160 So. 3d 385, 389 (Fla. 2015) (citing § 48.21(1), Fla. Stat.) Under Florida law, there is a hierarchy fo…
citing § 48.21(1), Fla. Stat.
green TAMARA CARUS v. COVE AT ISLES AT BAYSHORE HOMEOWNERS ASSOCIATION, INC. (2022)
Rule Authority · Fla. Dist. Ct. App.
Namely, a return of service shall note: “(1) the date and time that the pleading comes to hand or is received by the process server, (2) the date and time that process is served, (3) the manner of service, and (4) the name of the person served . . . .” Koster v. Sullivan, 160 So. 3d 385, 389 (Fla. 2015).
green JONATHAN MICHAEL SCHULER v. SANDY T. FOX, P.A. (2022)
Rule Authority · Fla. Dist. Ct. App.
Rorick as trustee for the bondholders’ committee.”); Papadakos v. Spooner, 186 So. 2d 786 , 786–87 (Fla. 3d DCA 1966) (“The complaint brought by [the attorney] against [the clients] alleged, in part, that . . . (5) [the client] agreed ‘that a reasonable fee would be paid to [the attorney].’”). 11 In Koster v. Sullivan, 160 So. 3d 385, 389 (Fla. 2015), the Florida Supreme Court explained that a return of service is regular on its face if it includes the statutory factors cont…
green United States v. Faro (2022)
Quote Authority · M.D. Fla. · signal: see
See Koster v. Sullivan, 160 So. 3d 385, 388 (Fla. 2015) (“Statutes governing service of process must be strictly construed and enforced.” And when “the statutes point out the mode of acquiring jurisdiction over the person, it must be strictly pursued.”) (citations omitted); Shurman v. Atl.
“Statutes governing service of process must be strictly construed and enforced.” And when “the statutes point out the mode of acquiring jurisdiction over the person, it must be strictly pursued.”
green DePoalo v. The Bank of New York Mellon (2021)
Rule Authority · M.D. Fla.
Florida law permits process to be served on the registered agent of a corporation, see Fla. Stat. § 48.081 , but compliance with that statute must be strictly construed, see, e.g., Koster v. Sullivan, 160 So. 3d 385, 388 (Fla. 2015).
green BCP Management, LLC v. Deutsche Bank National Trust Company (2021)
Rule Authority · M.D. Fla.
“Statutes governing service of process must be strictly construed and enforced.” Koster v. Sullivan, 160 So. 3d 385, 388 (Fla. 2015).
green Murphy v. Cach, LLC (2017)
Rule Authority · Fla. Dist. Ct. App.
Further, “[statutes governing service of process must be strictly construed and enforced.” Koster v. Sullivan, 160 So.3d 385, 388 (Fla. 2015) (citing Shurman v. Atl.
citing Shurman v. Atl. Mortg. & Inv. Corp., 795 So.2d 952, 954 (Fla. 2001)
green Coutts v. Sabadell United Bank, N.A. (2016)
Rule Authority · Fla. Dist. Ct. App.
Coutts further contends that Saba-dell failed to establish proper service of process because the return of service did not include the necessary information to show compliance with the provisions of section 48.031(6)(a), which permits substitute service on a private mailbox “only if the process server determines that the person to‘ be served maintains a [private] mailbox .,. at that location.” However, the premise of Coutts’s argument has already been considered and rejected…
green Arlene Preudhomme v. Christopher Matthews and Garth Bailey (2016)
Rule Authority · Fla. Dist. Ct. App.
A plaintiff seeking to “invoke the court’s jurisdiction bears the burden of proving proper service,” which requires a showing that the return of service is “facially valid or regular on its face.” Koster v. Sullivan, 160 So.3d 385, 389 (Fla.2015).
green Janet Mauro and Dennis Quinn v. Wells Fargo Bank, N.A. (2015)
Rule Authority · Fla. Dist. Ct. App.
The law is well-settled that “[t]he return of service is the instrument a court relies on to determine whether jurisdiction over an individual has been established.” Roster v. Sullivan, 160 So.3d 385, 388 (Fla.2015).
green Morgan Stanley Smith Barney, LLC v. Gibraltar Private Bank & Trust Co. (2015)
Rule Authority · Fla. Dist. Ct. App.
“If the return [of service] is regular on its face, then the service of process is presumed to be valid and the party challenging service-has the burden of overcoming that presumption by clear and convincing evidence.” Koster v. Sullivan, 160 So.3d 385, 389 (Fla.2015) (quoting Re-Emp’l Servs., Ltd. v. Nat’l Loan Acquisitions Co., 969 So.2d 467, 471 (Fla. 5th DCA 2007)); Bank of Am., N.A. v. Bornstein, 39 So.3d 500, 503 (Fla. 4th DCA 2010); see also Klosenski v. Flaherty, 116…
green DENSYL ALEXIS DIAZ RODRIGUEZ v. HSBC BANK USA, NATIONAL ASSOCIATION, AS TRUSTEE ETC. (2022)
Cited · Fla. Dist. Ct. App. · signal: see · 3 citations in this opinion
See Koster, 160 So. 3d at 389 .
green Navas Bar & Grill, Inc., D/B/A 1701 Restaurant & Lounge v. Tapias (2025)
Cited · Fla. Dist. Ct. App. · signal: see · 2 citations in this opinion
See KMG, 393 So. 3d at 245-46 (quoting Koster v. Sullivan, 160 So. 3d 385, 388 (Fla. 2015)).
green Navas Bar & Grill, Inc., D/B/A 1701 Restaurant & Lounge v. Tapias (2025)
Cited · Fla. Dist. Ct. App. · signal: see · 2 citations in this opinion
See KMG, 393 So. 3d at 245-46 (quoting Koster v. Sullivan, 160 So. 3d 385, 388 (Fla. 2015)).
green Milfort v. Rambosk (2021)
Cited · M.D. Fla. · signal: see
See Koster v. Sullivan, 160 So. 3d 385, 388 (Fla. 2015).
green Alvarez v. Gregory Hvac LLC (2021)
Cited · M.D. Fla. · signal: see
See Koster v. Sullivan, 160 So. 3d 385, 388 (Fla. 2015).
green Souza v. NI Holdings, LLC (2018)
Cited · Fla. Dist. Ct. App. · signal: see
See Koster v. Sullivan , 160 So.3d 385 , 389 (Fla. 2015) (holding that if the return of service is regular on its face, service of process is presumed to be valid, *383 and the party challenging service has the burden of overcoming that presumption by clear and convincing evidence); Robles-Martinez v. Diaz, Reus & Targ, LLP , 88 So.3d 177 (Fla. 3d DCA 2011) (same).
holding that if the return of service is regular on its face, service of process is presumed to be valid, *383 and the party challenging service has the burden of overcoming that presumption by clear and convincing evidence
green Urbieta Oil, Inc. v. Ruiz (2016)
Cited · Fla. Dist. Ct. App. · signal: see
See Koster v. Sullivan, 160 So.3d 385 (Fla.2015); Morgan Stanley Smith Barney, LLC v. Gibraltar Private Bank & Trust Co., 162 So.3d 1058, 1060 (Fla. 3d DCA 2015)(stating “[i]f the return [of service] is regular on its face, then the service of process is presumed to be valid and the party challenging service has the burden of overcoming that presumption by clear and convincing evidence.”)(quoting Koster, 160 So.3d at 389 ).