limitation rule (Florida) · Go Syfert
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limitation rule in Florida

40 Florida opinions name it 2 courts 1944–2024 4 in the last five years

The cases below were cited by Florida courts in a sentence that names this issue. Sides come from how each citing opinion treated the case (Syfertize flag on that citation), so a case can appear on both: that is where the law is contested. A red or yellow chip is the case's own overall treatment.

Followed or applied (19)

CaseFollowedCited
Gelco Convention Services v. Pettengillgreen
fladistctapp · 1998 · cited in 2 Florida opinions naming this issue, 2004–2017
2 sentences

2017Cohen at 405 (quoting Gelco Convention Servs. v. Pettengill, 710 So.2d 581, 583 (Fla. 4th DCA 1998)).

2004Gelco Convention Servs. v. Pettengill, 710 So.2d 581, 583 (Fla. 4th DCA 1998).

22
Nielsen v. City of Sarasotagreen
fla · 1960 · cited in 3 Florida opinions naming this issue, 1987–2016
2 sentences

2016Stanley v. Marceaux, 991 So.2d 938, 940 (Fla. 4th DCA 2008) (emphasis added) (quoting Nielsen v. City of Sarasota, 117 So.2d 731, 733 (Fla.1960)).

2014Id. at 733 .

13
State v. Michaelsgreen
fla · 1984 · cited in 1 Florida opinions naming this issue, 2024–2024
1 sentence

2024Before Jackson, the Court already had observed a traditional limitation on the rule: when an available and competent witness is “equally available to both parties, no inference should be drawn or comments made on the failure of either party to call the witness.” State v. Michaels, 454 So. 2d 560, 562 (Fla. 1984).

11
LOT v. Stategreen
fladistctapp · 2009 · cited in 1 Florida opinions naming this issue, 2018–2018
1 sentence

2018See Lot v. State, 13 So. 3d 1121, 1123 (Fla. 3d DCA 2009) (“On appeal, we review the trial court’s limitation of defense counsel’s cross-examination for an abuse of discretion.”).

11
Florida Carry, Inc. v. University of Floridagreen
fladistctapp · 2015 · cited in 1 Florida opinions naming this issue, 2018–2018
1 sentence

2018In Florida Carry, Inc. v. University of Florida, 180 So. 3d 137, 148-49 (Fla. 1st DCA 2015) (UF), we held that officers, employees, and agents of the State or its subdivisions were not immune from suit under section 790.33 by operation of the limitation in the waiver of sovereign immunity contained in section 768.28(9)(a), Florida Statutes.

11
Cohen v. Arvingreen
fladistctapp · 2004 · cited in 1 Florida opinions naming this issue, 2017–2017
1 sentence

2017Cohen at 405 (quoting Gelco Convention Servs. v. Pettengill, 710 So.2d 581, 583 (Fla. 4th DCA 1998)).

11
Stanley v. Marceauxgreen
fladistctapp · 2008 · cited in 1 Florida opinions naming this issue, 2016–2016
1 sentence

2016Stanley v. Marceaux, 991 So.2d 938, 940 (Fla. 4th DCA 2008) (emphasis added) (quoting Nielsen v. City of Sarasota, 117 So.2d 731, 733 (Fla.1960)).

11
Dickinson v. Segalgreen
fla · 1969 · cited in 1 Florida opinions naming this issue, 2015–2015
1 sentence

2015See Dickinson v. Segal, 219 So.2d 435, 438 (Fla.1969) (“[W]e, by virtue of the authority of that case, recognize this exception but decline to extend it beyond the facts involved there.”); Md.

11
Sexton v. Stategreen
fla · 1997 · cited in 1 Florida opinions naming this issue, 2013–2013
1 sentence

2013The fact that “a photograph is prejudicial does not justify its exclusion as evidence; rather, a relevant photograph must be unfairly prejudicial to be excluded.” Hampton v. State, 103 So.3d 98, 115 (Fla.2012) (citing Sexton v. State, 697 So.2d 833, 837 (Fla.1997), cert. denied, — U.S.-, 133 S.Ct. 2027 , 185 L.Ed.2d 892 (2013)).

11
Hampton v. Stategreen
fla · 2012 · cited in 1 Florida opinions naming this issue, 2013–2013
1 sentence

2013The fact that “a photograph is prejudicial does not justify its exclusion as evidence; rather, a relevant photograph must be unfairly prejudicial to be excluded.” Hampton v. State, 103 So.3d 98, 115 (Fla.2012) (citing Sexton v. State, 697 So.2d 833, 837 (Fla.1997), cert. denied, — U.S.-, 133 S.Ct. 2027 , 185 L.Ed.2d 892 (2013)).

11
Moore v. Stategreen
fla · 1997 · cited in 1 Florida opinions naming this issue, 2009–2009
1 sentence

2009Moore v. State, 701 So.2d 545, 549 (Fla.1997) (“Limitation of cross-examination is subject to an abuse of discretion standard.”); accord Diaz v. State, 747 So.2d 1021, 1023 (Fla. 3d DCA 1999).

11
Diaz v. Stategreen
fladistctapp · 1999 · cited in 1 Florida opinions naming this issue, 2009–2009
1 sentence

2009Moore v. State, 701 So.2d 545, 549 (Fla.1997) (“Limitation of cross-examination is subject to an abuse of discretion standard.”); accord Diaz v. State, 747 So.2d 1021, 1023 (Fla. 3d DCA 1999).

11
REUTER RECYCLING OF FL. INC. v. City of Dania Beachgreen
fladistctapp · 2003 · cited in 1 Florida opinions naming this issue, 2006–2006
1 sentence

2006See Reuter Recycling, 859 So.2d at 1273 (concluding that that arbitration provision was unambiguous and "expressly excludes time-barred claims from the agreement to arbitrate," and that the trial court erred in finding that the parties agreed "to have the arbitrators determine arbitrability as to time-barred claims").

11
Geiger ex rel. Geiger v. Mather of Lakeland, Inc.green
fladistctapp · 1968 · cited in 1 Florida opinions naming this issue, 2002–2002
1 sentence

2002However, Fino recognized the limitation on that rule that the "unfavorable inference which may be drawn from the failure of a party to testify is not warranted when there has been a sufficient explanation for such absence or failure to testify." Id. (quoting Geiger v. Mather of Lakeland, Inc., 217 So.2d 897, 898 (Fla. 4th DCA 1968)) (emphasis in original).

11
Massey v. Seaboard Air Line Railroadgreen
fla · 1962 · cited in 1 Florida opinions naming this issue, 2000–2000
1 sentence

2000See Massey v. Seaboard Air Line R.R., 142 So.2d 296 (Fla. 1962).

11
Publix Super Markets, Inc. v. Schmidtgreen
fladistctapp · 1987 · cited in 1 Florida opinions naming this issue, 1997–1997
1 sentence

1997Publix, 509 So.2d at 978 (emphasis added); see also Voelker v. Combined Ins.

11
In Re Guardianship of DA McW.green
fladistctapp · 1983 · cited in 1 Florida opinions naming this issue, 1997–1997
1 sentence

1997In re Guardianship of D.A., McW., 429 So.2d 699, 702 (Fla. 4th DCA 1983) (quoting State ex rel.

11
Scientific Games, Inc. v. Dittler Bros., Inc.green
fladistctapp · 1991 · cited in 1 Florida opinions naming this issue, 1992–1992
11
Bryan v. Stategreen
fla · 1988 · cited in 1 Florida opinions naming this issue, 1989–1989
11

Distinguished, questioned or overruled (0)

CaseNegativeCited
No negative-treatment citations attached to this issue in Florida. Read the followed side critically anyway.

Also cited on this issue (30)

CaseCitedYears
State Ex Rel. Sparks v. Reeves green
fla · 1957
2 sentences

2021This is a rule older than the common law itself . . . .” In fact, “the only limitation on this rule of parental privilege is that as between the parent and the child the ultimate welfare of the child itself must be controlling.” Id.

2016Specifically, “the only limitation on this rule of parental privilege is that as between the parent and the child the ultimate welfare of the child must be controlling.” Id. (quoting Sparks, 97 So.2d at 20 ).

31991–2021
Padgett v. Dept. of Health & Rehab. Services green
fla · 1991
2 sentences

2024And third, we - 11 - reiterated that the “the only limitation on this rule of parental privilege is that as between the parent and the child[,] the ultimate welfare of the child must be controlling.” Id. (quoting Padgett, 577 So. 2d at 570 ).

2024And third, we - 11 - reiterated that the “the only limitation on this rule of parental privilege is that as between the parent and the child[,] the ultimate welfare of the child must be controlling.” Id. (quoting Padgett, 577 So. 2d at 570 ).

22024–2024
S.M., etc. v. Florida Department of Children and Families green
fla · 2016
2 sentences

2024And third, we - 11 - reiterated that the “the only limitation on this rule of parental privilege is that as between the parent and the child[,] the ultimate welfare of the child must be controlling.” Id. (quoting Padgett, 577 So. 2d at 570 ).

2024And third, we - 11 - reiterated that the “the only limitation on this rule of parental privilege is that as between the parent and the child[,] the ultimate welfare of the child must be controlling.” Id. (quoting Padgett, 577 So. 2d at 570 ).

22024–2024
Kent v. Burdick green
fladistctapp · 1991
2 sentences

2002Id.

1994Id.

21994–2002
In Re Estate of Pratt green
fla · 1956
2 sentences

1977The appellee argues that the supreme court in the case of In re Pratt’s Estate, 88 So.2d 499 (Fla.1956) precludes application of the doctrine where a particular gift fails in an otherwise valid will.

1977The appellee argues that the supreme court in the case of In re Pratt's Estate, 88 So.2d 499 (Fla. 1956) precludes application of the doctrine where a particular gift fails in an otherwise valid will.

21977–1977
Jackson v. State green
fla · 1991
1 sentence

2024Jackson reaffirmed this limitation on the missing witness rule and clarified that the factfinder may draw an adverse inference from a missing witness where the defendant “voluntarily assumes some burden of proof by asserting the defenses of alibi, self-defense, and defense of others, relying on facts that could be elicited only from a witness who is not equally available to the state.” 575 So. 2d at 188 .

12024–2024
PETERSON BALTAZARE SIMBERT v. STATE OF FLORIDA green
fladistctapp · 2017
1 sentence

2019While the attorney might well have argued that a reasonable doubt arose from the inability to pinpoint the victim’s whereabouts after she returned home with her mother, the trial court properly sustained an objection to the argument that she wandered down the hall, unsupervised, in the apartment complex, in the absence of any evidence to support that speculation. -3- Consistent with Simbert, 226 So. 3d at 888 , we reverse the conviction on Count I and remand to the trial court for the entry of a judgment of acquittal on that count. 1 WARNER, J., and WEISS, DALIAH, Associate Judge, concur. * *

12019–2019
Brooks v. New Hampshire green
scotus · 2013
1 sentence

2013The fact that “a photograph is prejudicial does not justify its exclusion as evidence; rather, a relevant photograph must be unfairly prejudicial to be excluded.” Hampton v. State, 103 So.3d 98, 115 (Fla.2012) (citing Sexton v. State, 697 So.2d 833, 837 (Fla.1997), cert. denied, — U.S.-, 133 S.Ct. 2027 , 185 L.Ed.2d 892 (2013)).

12013–2013
Hughes v. Indiana green
scotus · 2013
1 sentence

2013The fact that “a photograph is prejudicial does not justify its exclusion as evidence; rather, a relevant photograph must be unfairly prejudicial to be excluded.” Hampton v. State, 103 So.3d 98, 115 (Fla.2012) (citing Sexton v. State, 697 So.2d 833, 837 (Fla.1997), cert. denied, — U.S.-, 133 S.Ct. 2027 , 185 L.Ed.2d 892 (2013)).

12013–2013
cluster 308230 green
ca3 · 1973
1 sentence

2007See § 672.719; Council Bros., Inc. v. Ray Burner Co., 473 F.2d 400 (5th Cir.1973) (interpreting Florida law).

12007–2007
FL v. Department of Children and Families green
fladistctapp · 2003
1 sentence

2003In Padgett , the court explained: In fact, "the only limitation on this rule of parental privilege is that as between the parent and the child the ultimate welfare of the child itself must be controlling." Id.

12003–2003
Fino v. Nodine green
fladistctapp · 1995
1 sentence

2002However, Fino recognized the limitation on that rule that the "unfavorable inference which may be drawn from the failure of a party to testify is not warranted when there has been a sufficient explanation for such absence or failure to testify." Id. (quoting Geiger v. Mather of Lakeland, Inc., 217 So.2d 897, 898 (Fla. 4th DCA 1968)) (emphasis in original).

12002–2002
Courtenay v. DHRS neutral
fladistctapp · 1991
1 sentence

1992See also, Scientific Games v. Dittler Bros., Inc., 586 So.2d 1128 (Fla. 1st DCA 1991); Courtenay v. Department of Health & Rehabilitative Services, 581 So.2d 621 (Fla. 5th DCA 1991).

11992–1992
McKoy v. United States green
dc · 1970
11991–1991
General Accident Fire & Life Assurance Corporation v. Donovan green
cadc · 1958
11991–1991
HOLYOKE MUT. INS., ETC. v. Concrete Equipment green
fladistctapp · 1981
11991–1991
Ins. Co. of North America v. Avis Rent-A-Car green
fla · 1977
11985–1985
Housing Inv. Corp. v. Carris green
fladistctapp · 1980
11985–1985
Local Lodge No. 1424, International Ass'n of MacHinists v. National Labor Relations Board green
scotus · 1960
11981–1981
Atlantic Coast Line Railroad v. Dexter green
· 1905
11977–1977
Florida Nursery & Landscape Co. v. Nally neutral
fladistctapp · 1961
11962–1962
Belden v. Lynch green
fladistctapp · 1961
11962–1962
Tucker Brothers, Inc. v. Menard green
fla · 1956
11960–1960
Epperson v. Epperson green
fla · 1958
11959–1959
Johns v. Johns neutral
fladistctapp · 1959
11959–1959
Montverde Development Corp. v. Howey-In-The-Hills green
fla · 1931
11950–1950
Crumbley v. City of Jacksonville green
fla · 1931
11950–1950
Wilson & Co. v. City of Jacksonville green
ca5 · 1948
11950–1950
Fillyau v. Laverty green
fla · 1850
11944–1944
Browne v. Browne green
fla · 1880
11944–1944

Statutes the citing opinions construe

FL § 39.806 (5) FL § 39.810 (5)

Counted by distinct opinions that both name this issue and are annotated to the section; sections every opinion cites regardless of issue are not filtered here, so read the counts against the total above.

Where else courts name it

TX 111 (1880–2025) NY 90 (1849–2023) CA 85 (1902–2025) IL 80 (1874–2025) PA 50 (1828–2021) FL 40 (1944–2024) MO 36 (1878–2024) MD 27 (1879–2021) WA 27 (1896–2024) AL 25 (1876–2015) MI 22 (1889–2023) MA 21 (1838–2015) MN 19 (1884–2015) GA 18 (1895–2023) NJ 18 (1871–2023) WI 18 (1897–2016) NC 17 (1904–2022) VT 17 (1881–2024) OH 16 (1845–2019) MS 16 (1925–2022) TN 16 (1940–2024) IA 16 (1885–2023) VA 16 (1971–2025) OK 15 (1915–2016) CO 15 (1903–2018) OR 14 (1902–2025) KY 13 (1923–2021) CT 13 (1856–2011) KS 12 (1873–2002) LA 12 (1945–2016) WY 12 (1894–2025) NM 12 (1893–2011) IN 10 (1871–2007) SC 8 (1967–2023) DC 8 (1973–2022) WV 7 (1893–1999) HI 7 (1908–2025) SD 6 (1928–2011) ND 6 (1890–2017) ID 6 (1940–2014) ME 6 (1908–2022) AZ 6 (1936–2017) AR 5 (1941–2016) MT 5 (1932–2000) UT 4 (1964–2020) NH 4 (1912–2024) AK 3 (1977–1984) RI 3 (1960–2011) DE 3 (1966–2026) NE 3 (1894–2022) NV 2 (1939–2017) PR 2 (1945–1956)

Opinions by the citing court's state. A doctrine retained in one state and abandoned in another shows up here as a year span that stalls.

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