specificity requirement in Florida

2026“Based on the clear wording of the rule, the specificity requirement applies to both temporary and permanent injunctions.” Premier Lab Supply, 10 So. 3d at 207 ; see also Hasley v. Harrell, 971 So. 2d 149, 152 (Fla. 2d DCA 2007).

2009See Hasley v. Harrell, 971 So.2d 149, 152 (Fla. 2d DCA 2007) (reclassifying a temporary injunction as a permanent injunction and reversing it because its form was deficient under the governing rule and statute).

2026“Based on the clear wording of the rule, the specificity requirement applies to both temporary and permanent injunctions.” Premier Lab Supply, 10 So. 3d at 207 ; see also Hasley v. Harrell, 971 So. 2d 149, 152 (Fla. 2d DCA 2007).

2011See Premier Lab Supply, Inc. v. Chemplex Indus., Inc., 10 So.3d 202, 206-07 (Fla. 4th DCA 2009).

2026Health Tr. of Dade Cnty., 661 So. 2d 1296, 1298 (Fla. 3d DCA 1995) (“An appellate court is reactive; it can only review asserted errors made by lower tribunals such as courts and administrative agencies.

2026The purpose of this specificity requirement is to permit the court to determine whether the movant has made a prima facie showing which would justify relief from judgment, and is not merely rehashing matters explored at trial.”) (citations omitted); Hembd v. Dauria, 859 So. 2d 1238, 1240 (Fla. 4th DCA 2003) (“To obtain a hearing on her rule 1.540(b)(3) motion, the law required Hembd to demonstrate a prima facie case of fraud, not just nibble at the edges of the concept.”); see also Sierra by Sierra v. Pub.

2021See also Rusniaczek v. Tableau Fine Art Grp., Inc., 139 So. 3d 355, 357-58 (Fla. 3d DCA 2014) (explaining that the “purpose of this specificity requirement is to permit the court ‘to determine whether the movant has made a prima facie showing which would justify relief from judgment,’ and is not merely rehashing matters explored at trial”) (quotation omitted). 2

2016See Thayer v. Chico’s FAS, Inc., 98 So. 3d 766, 768 (Fla. 1st DCA 2012); Wyeth/Pharma Field Sales v. Toscano, 40 So. 3d 795, 802 (Fla. 1st DCA 2010).

2016Appellant’s “challenge to the sufficiency of the evidence to support the judgment is cognizable on appeal pursuant to rule 1.530(e) [Florida Rules of Civil Procedure] regardless of the specificity of defense counsel’s numerous objections during the bench trial.” Burdeshaw v. Bank of New York Mellon, 148 So. 3d 819, 822 (Fla. 1st DCA 2014); see also Wolkoff v. Am.

2016Appellant’s “challenge to the sufficiency of the evidence to support the judgment is cognizable on appeal pursuant to rule 1.530(e) [Florida Rules of Civil Procedure] regardless of the specificity of defense counsel’s numerous objections during the bench trial.” Burdeshaw v. Bank of New York Mellon, 148 So.3d 819, 822 (Fla. 1st DCA 2014); see also Wolkoff v. Am.

2016See Thayer v. Chico’s FAS, Inc., 98 So. 3d 766, 768 (Fla. 1st DCA 2012); Wyeth/Pharma Field Sales v. Toscano, 40 So. 3d 795, 802 (Fla. 1st DCA 2010).

2011See Cromartie, 70 So.3d at 563 (holding that a trial judge’s arbitrary sentencing policy was fundamental error). “[F]or an error to be so fundamental that it can be raised for the first time on appeal, the error must be basic to *837 the judicial decision under review and equivalent to a denial of due process.” Jackson, 983 So.2d at 575 (quoting Hopkins v. State, 632 So.2d 1372, 1374 (Fla.1994)). “[I]n order to be considered fundamental, an error must be serious.

2011See Cromartie, 70 So.3d at 563 (holding that a trial judge’s arbitrary sentencing policy was fundamental error). “[F]or an error to be so fundamental that it can be raised for the first time on appeal, the error must be basic to *837 the judicial decision under review and equivalent to a denial of due process.” Jackson, 983 So.2d at 575 (quoting Hopkins v. State, 632 So.2d 1372, 1374 (Fla.1994)). “[I]n order to be considered fundamental, an error must be serious.

2011See Cromartie, 70 So.3d at 563 (holding that a trial judge’s arbitrary sentencing policy was fundamental error). “[F]or an error to be so fundamental that it can be raised for the first time on appeal, the error must be basic to *837 the judicial decision under review and equivalent to a denial of due process.” Jackson, 983 So.2d at 575 (quoting Hopkins v. State, 632 So.2d 1372, 1374 (Fla.1994)). “[I]n order to be considered fundamental, an error must be serious.

2002Co. v. Hingson, 808 So.2d 197, 199 (Fla.2002) (holding that the old rule required an offer to multiple plaintiffs to be apportioned among the plaintiffs, even without the specificity requirement that was added to the rule in 1997); Dudley v. McCormick, 799 So.2d 436, 441 (Fla. 1st DCA 2001) (holding that Rule 1.442 requires that a joint offer made by a single defendant to two separate plaintiffs must specify the amount to go to each plaintiff); McFarland & Son, Inc. v. Basel, 727 So.2d 266, 270 (Fla. 5th DCA 1999) ("[A] general offer to a group of defendants without assigning each defendant a

2002See C & S Chem., Inc. v. McDougald, 754 So.2d 795 , 797-98 n. 3 (Fla. 2d DCA 2000).

2002Co. v. Hingson, 808 So.2d 197, 199 (Fla.2002) (holding that the old rule required an offer to multiple plaintiffs to be apportioned among the plaintiffs, even without the specificity requirement that was added to the rule in 1997); Dudley v. McCormick, 799 So.2d 436, 441 (Fla. 1st DCA 2001) (holding that Rule 1.442 requires that a joint offer made by a single defendant to two separate plaintiffs must specify the amount to go to each plaintiff); McFarland & Son, Inc. v. Basel, 727 So.2d 266, 270 (Fla. 5th DCA 1999) ("[A] general offer to a group of defendants without assigning each defendant a

2002Meyers, 771 So.2d 1202, 1204 (Fla. 4th DCA 2000) (holding that a general offer made to two defendants was deficient even though there was an indemnification agreement between the two defendants); but see Safelite Glass Corp. v. Samuel, 771 So.2d 44, 45-46 (Fla. 4th DCA 2000) (holding that an offer made to two defendants was not deficient for failure to apportion the amount between those defendants because one defendant was vicariously liable for the other defendant's negligence).

2002Co. v. Hingson, 808 So.2d 197, 199 (Fla.2002) (holding that the old rule required an offer to multiple plaintiffs to be apportioned among the plaintiffs, even without the specificity requirement that was added to the rule in 1997); Dudley v. McCormick, 799 So.2d 436, 441 (Fla. 1st DCA 2001) (holding that Rule 1.442 requires that a joint offer made by a single defendant to two separate plaintiffs must specify the amount to go to each plaintiff); McFarland & Son, Inc. v. Basel, 727 So.2d 266, 270 (Fla. 5th DCA 1999) ("[A] general offer to a group of defendants without assigning each defendant a

1978See, e.g., Russell v. U.S., 369 U.S. 749 , 82 S.Ct. 1038 , 8 L.Ed.2d 240 (1962); State v. Smith, 240 So.2d 807 (Fla. 1970); Victer v. State, 174 So.2d 544 (Fla. 1965); and State v. Jones, 312 So.2d 483 (Fla. 4th DCA 1975).

1978See, e.g., Russell v. U.S., 369 U.S. 749 , 82 S.Ct. 1038 , 8 L.Ed.2d 240 (1962); State v. Smith, 240 So.2d 807 (Fla. 1970); Victer v. State, 174 So.2d 544 (Fla. 1965); and State v. Jones, 312 So.2d 483 (Fla. 4th DCA 1975).