administrative finality doctrine (Florida) · Go Syfert
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administrative finality doctrine in Florida

13 Florida opinions name it 2 courts 1981–2026 2 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 (7)

CaseFollowedCited
Austin Tupler Trucking, Inc. v. Hawkinsgreen
fla · 1979 · cited in 4 Florida opinions naming this issue, 1981–2017
2 sentences

2017The administrative finality doctrine is based on the idea that “there must be a 'terminal point in every proceeding both administrative and judicial, at which the parties and the public may rely on a decision as being final and dispositive of the rights and issues therein.’ ” Fla. Power Corp. v. Garcia, 780 So.2d 34, 44 (Fla. 2001) (quoting Austin Tupler Trucking, Inc. v. Hawkins, 377 So.2d 679, 681 (Fla. 1979)).

1991Peoples Gas Systems, Inc. v. Mason, 187 So.2d 335, 339 (Fla.1966), and Austin Tupler Trucking, Inc. v. Hawkins, 377 So.2d 679 (Fla.1979), recognize an exception to the doctrine of administrative finality where there is a demonstrated public interest.

24
Florida Power & Light Co. v. Beardgreen
fla · 1993 · cited in 2 Florida opinions naming this issue, 2009–2026
2 sentences

2026See Fla. Power & Light Co. v. Beard, 626 So. 2d 660, 662 (Fla. 1993) (“[T]his 4 Court has recognized exceptions to the doctrine of administrative finality based on a significant change of circumstances or a demonstrated public interest.”).

2009See Fla. Power & Light Co. v. Beard, 626 So.2d 660 (Fla.1993); Univ.

22
Delray Medical Center, Inc. v. State Agency for Health Care Administrationgreen
fladistctapp · 2009 · cited in 2 Florida opinions naming this issue, 2015–2019
2 sentences

2019Ctr., Inc., 5 So. 3d at 29 (“Florida courts do not apply the doctrine of administrative finality when there has been a significant change of circumstances or there is a demonstrated public interest.”); Univ.

2015Ctr., Inc. v. State, Agency for Health Care Admin., 5 So.3d 26, 29 (Fla. 4th DCA 2009) (“Florida courts do not apply the doctrine of administrative finality when there has been a significant change of circumstances or there is a demonstrated public interest”).

22
Peoples Gas System, Inc. v. Masongreen
fla · 1966 · cited in 5 Florida opinions naming this issue, 1981–2019
2 sentences

2019We explained the doctrine of administrative finality in Peoples Gas System, Inc. v. Mason , 187 So. 2d 335 , 339 (Fla. 1966) : [O]rders of administrative agencies must eventually pass out of the agency's control and become final and no longer subject to modification.

1996This Court explained the doctrine of administrative finality in Peoples Gas System, Inc. v. Mason, 187 So.2d 335 (Fla.1966): [Ojrders of administrative agencies must eventually pass out of the agency’s control and become final and no longer subject to modification.

15
Holiday Inns, Inc. v. City of Jacksonvillegreen
fladistctapp · 1996 · cited in 1 Florida opinions naming this issue, 2019–2019
1 sentence

2019Hosp., Ltd. v. State, Agency for Health Care Admin., 697 So. 2d 909, 912 (Fla. 1st DCA 1997) (“res judicata cannot bar a subsequent application for a permit if the second application is ‘supported by new facts, changed conditions, or additional submissions by the applicant.’”); Holiday Inns, Inc., 678 So. 2d at 528 (same).

11
University Hosp. v. AHCAgreen
fladistctapp · 1997 · cited in 1 Florida opinions naming this issue, 2019–2019
1 sentence

2019Hosp., Ltd. v. State, Agency for Health Care Admin., 697 So. 2d 909, 912 (Fla. 1st DCA 1997) (“res judicata cannot bar a subsequent application for a permit if the second application is ‘supported by new facts, changed conditions, or additional submissions by the applicant.’”); Holiday Inns, Inc., 678 So. 2d at 528 (same).

11
Florida Power Corp. v. Garciagreen
fla · 2001 · cited in 1 Florida opinions naming this issue, 2017–2017
1 sentence

2017The administrative finality doctrine is based on the idea that “there must be a 'terminal point in every proceeding both administrative and judicial, at which the parties and the public may rely on a decision as being final and dispositive of the rights and issues therein.’ ” Fla. Power Corp. v. Garcia, 780 So.2d 34, 44 (Fla. 2001) (quoting Austin Tupler Trucking, Inc. v. Hawkins, 377 So.2d 679, 681 (Fla. 1979)).

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 (5)

CaseCitedYears
Lee Memorial Health System etc. v. State of Florida, Agency For Agency For Health etc. green
fladistctapp · 2019
2 sentences

2024Third, the statutory change did not supplant the common law doctrine of administrative finality. 2 In Gulf Coast, in response to the Centers for Medicare and Medicaid Services’ federal audit, the Agency initiated the Undocumented Alien Project (“the Project”). 272 So. 3d at 433 .

2024“Under the flag of the Project, the Agency began audits of all paid in-patient hospital claims for emergency services provided to alien recipients in Florida between July 2005 and June 2010.” Id. at 437 .

12024–2024
CITRUS CTY. v. Southern States Utilities green
fladistctapp · 1995
1 sentence

1997Four months after rendition of the final order now appealed, this court decided Citrus County v. Southern States Utilities, supra , reversing the March 22, 1993, order on the ground that the PSC exceeded its statutory authority when it approved uniform statewide rates without first making a finding that SSU's facilities and land were "functionally related" in utility service delivery so as to comprise a single system.

11997–1997
Jet Air Freight v. Jet Air Freight Delivery, Inc. green
fladistctapp · 1972
1 sentence

1981Rather than addressing directly the issue of exactly when and how the contested nature of the adjustment clause was established, the utilities in this proceeding contend that public counsel is now asserting a collateral attack upon Order No. 6357 issued in 1974, which is prohibited by either the doctrine of administrative finality, Austin Tupler Trucking, Inc. v. Hawkins, 377 So.2d 679 (Fla.1979); Peoples Gas System, Inc. v. Mason, 187 So.2d 335 (Fla.1966), or the doctrines of collateral estoppel and res judica-ta, Jet Air Freight v. Jet Air Freight Delivery, Inc., 264 So.2d 35 (Fla. 3d DCA),

11981–1981
Chrysler Credit Corporation v. Rehurek green
fla · 1972
1 sentence

1981Rather than addressing directly the issue of exactly when and how the contested nature of the adjustment clause was established, the utilities in this proceeding contend that public counsel is now asserting a collateral attack upon Order No. 6357 issued in 1974, which is prohibited by either the doctrine of administrative finality, Austin Tupler Trucking, Inc. v. Hawkins, 377 So.2d 679 (Fla.1979); Peoples Gas System, Inc. v. Mason, 187 So.2d 335 (Fla.1966), or the doctrines of collateral estoppel and res judica-ta, Jet Air Freight v. Jet Air Freight Delivery, Inc., 264 So.2d 35 (Fla. 3d DCA),

11981–1981
City of Miami v. Florida Public Service Commission green
fla · 1968
1 sentence

1981The utilities further contend that the arguments of public counsel are without merit because the findings and determinations of the commission are presumed to be valid and reasonable, absent clear and convincing showing to the contrary, City of Miami v. Florida Public Service Commission, 208 So.2d 249 (Fla.1968), and that it is not this Court’s responsibility to reweigh or reevaluate conflicting evidence, but only to ascertain whether the commission’s order is supported by competent, substantial evidence.

11981–1981

Where else courts name it

RI 30 (1983–2023) PA 15 (2009–2025) FL 13 (1981–2026) CA 3 (2019–2026) NY 3 (1983–2019)

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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