time requirements rule (Florida) · Go Syfert
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time requirements rule in Florida

13 Florida opinions name it 2 courts 1964–2023 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 (8)

CaseFollowedCited
Schussel v. Ladd Hairdressers, Inc.green
fladistctapp · 1999 · cited in 2 Florida opinions naming this issue, 2002–2005
2 sentences

2005That holding was, at least in part, premised on Schussel v. Ladd Hairdressers, Inc., 736 So.2d 776, 778 (Fla. 4th DCA 1999), which construed the provisions of section 768.79 and rule 1.442 to be punitive in nature and, therefore, subject to strict construction.

2002Grip, 788 So.2d at 265 (citing Schmidt v. Fortner, 629 So.2d 1036, 1040 (Fla. 4th DCA 1993)); see also Schussel, 736 So.2d at 778 (stating that the provisions of section 768.79 and rule 1.442 are punitive and must be strictly construed).

22
Millar Elevator Service Co. v. McGowangreen
fladistctapp · 2002 · cited in 1 Florida opinions naming this issue, 2023–2023
1 sentence

2023Co. v. McGowan, 819 So. 2d 145, 153 (Fla. 2d DCA 2002) (observing in the context of a jury trial that the preservation requirement “also promotes judicial economy and prevents ‘a party from rolling the dice with the jury, confident that an unvoiced objection will garner a new trial if the verdict is unfavorable’” (quoting Lowe Inv.

11
Goodman v. Goodmangreen
fladistctapp · 2011 · cited in 1 Florida opinions naming this issue, 2022–2022
1 sentence

2022See Goodman v. Joffe, 57 So. 3d 1001, 1002 (Fla. 4th DCA 2011) (“Our holding should not be read to mean that a party may ignore the time requirements imposed by Florida Rule of Civil Procedure 1.540, or that we countenance the practice of filing a motion and then allowing it to languish.

11
Sterling Factors v. US Bank Nat. Ass'ngreen
fladistctapp · 2007 · cited in 1 Florida opinions naming this issue, 2019–2019
1 sentence

2019See Sterling Factors Corp. v. U.S. Bank Nat’l Ass’n, 968 So. 2d 658, 665 (Fla. 2d DCA 2007) (stating that a voidable judgment “cannot be challenged at any time as void under rule 1.540(b)(4).”).

11
Hilbert v. Stategreen
fladistctapp · 1995 · cited in 1 Florida opinions naming this issue, 2010–2010
1 sentence

2010P. 3.850(b); Martell v. State, 676 So.2d 1030 (Fla. 3d DCA 1996) (stating that Rule 3.800 cannot be used to circumvent the strict time requirements of rule 3.850; fact-based challenges that sentences were unlawful must be raised on direct appeal or in rule 3.850 motion and not by way of rule 3.800); Hilbert v. State, 661 So.2d 895 (Fla. 3d DCA 1995) (“A motion to correct an illegal sentence filed pursuant to rule 3.800 challenging the validity of conviction and not the legality of sentence must be properly treated as a motion pursuant to rule 3.850 and not rule 3.800.”).

11
Smith v. Stategreen
fladistctapp · 2005 · cited in 1 Florida opinions naming this issue, 2005–2005
1 sentence

2005Florida Rule of Criminal Procedure 3.800(c) allows a court to modify a sentence "within 60 days after the imposition, or within 60 days after receipt ... of a mandate issued by the appellate court." In this case, the circuit court misapprehended the time requirements of rule 3.800(c) and failed to account for the "second opportunity for mitigation during the sixty days after issuance of the mandate that concluded [the] direct appeal." Smith v. State, 895 So.2d 488, 489 (Fla. 2d DCA 2005).

11
Schmidt v. Fortnergreen
fladistctapp · 1993 · cited in 1 Florida opinions naming this issue, 2002–2002
1 sentence

2002Grip, 788 So.2d at 265 (citing Schmidt v. Fortner, 629 So.2d 1036, 1040 (Fla. 4th DCA 1993)); see also Schussel, 736 So.2d at 778 (stating that the provisions of section 768.79 and rule 1.442 are punitive and must be strictly construed).

11
State v. Salzerogreen
fla · 1998 · cited in 1 Florida opinions naming this issue, 2000–2000
1 sentence

2000See, e.g., State v. Salzero, 714 So.2d 445, 447 (Fla.1998) (finding that "strict adherence to [the time requirements of a rule of criminal procedure] would not comport with the clear intent of this section as evident from the committee notes to the 1984 amendment of the rule").

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 (11)

CaseCitedYears
Martell v. State green
fladistctapp · 1996
1 sentence

2010P. 3.850(b); Martell v. State, 676 So.2d 1030 (Fla. 3d DCA 1996) (stating that Rule 3.800 cannot be used to circumvent the strict time requirements of rule 3.850; fact-based challenges that sentences were unlawful must be raised on direct appeal or in rule 3.850 motion and not by way of rule 3.800); Hilbert v. State, 661 So.2d 895 (Fla. 3d DCA 1995) (“A motion to correct an illegal sentence filed pursuant to rule 3.800 challenging the validity of conviction and not the legality of sentence must be properly treated as a motion pursuant to rule 3.850 and not rule 3.800.”).

12010–2010
Bottcher v. Walsh green
fladistctapp · 2002
1 sentence

2005It is undisputed that Mills's proposal for settlement was timely served, but prematurely filed with the court, some two years prior to trial. [3] We recognize that Bottcher v. Walsh, 834 So.2d 183 (Fla. 2d DCA 2002), holds that because the time requirements of rule 1.442 are to be strictly construed, a prematurely filed offer is void.

12005–2005
Grip Development, Inc. v. Coldwell Banker Residential Real Estate, Inc. green
fladistctapp · 2000
1 sentence

2002Grip, 788 So.2d at 265 (citing Schmidt v. Fortner, 629 So.2d 1036, 1040 (Fla. 4th DCA 1993)); see also Schussel, 736 So.2d at 778 (stating that the provisions of section 768.79 and rule 1.442 are punitive and must be strictly construed).

12002–2002
In Re Amendment to Fla. Rules of Crim. green
fla · 1996
1 sentence

1999Id.

11999–1999
In Re Amendment to Rules of Crim. Proced. green
fla · 1997
1 sentence

1998P.—Capital Post conviction Public Records Production, 700 So.2d 680 (Fla.1997), we granted that request, tolling the time requirements required by rule 3.852 through January 15, 1998, for the defendants listed in that order.

11998–1998
In Re Family Law Rules of Procedure green
fla · 1995
1 sentence

1995Accordingly, we reaffirm our adoption, effective January 1, 1996, of the amendments to the Florida Rules of Civil Procedure (attached to this opinion as appendix A) and the new Florida Family Law Rules of Procedure (attached to this opinion as appendix B), as provided in In re Family Law Rules of Procedure, 663 So.2d 1047 (Fla. 1995), and as modified herein.

11995–1995
Carter v. State green
fladistctapp · 1987
1 sentence

1988We find several instances in which the appellate courts of this state have refused to give legal significance to a defendant's pro se speedy trial demand under Rule 3.191, Florida Rules of Criminal Procedure, thereby implicating the time requirements of that rule, when the defendant was otherwise represented by counsel. [1] See, Beverly v. State, 516 So.2d 30 (Fla. 1st DCA 1987); Carter v. State, 509 So.2d 1126 (Fla. 5th DCA 1987); and Dickey v. McNeal, 445 So.2d 692 (Fla. 5th DCA 1984).

11988–1988
Beverly v. State green
fladistctapp · 1987
1 sentence

1988We find several instances in which the appellate courts of this state have refused to give legal significance to a defendant's pro se speedy trial demand under Rule 3.191, Florida Rules of Criminal Procedure, thereby implicating the time requirements of that rule, when the defendant was otherwise represented by counsel. [1] See, Beverly v. State, 516 So.2d 30 (Fla. 1st DCA 1987); Carter v. State, 509 So.2d 1126 (Fla. 5th DCA 1987); and Dickey v. McNeal, 445 So.2d 692 (Fla. 5th DCA 1984).

11988–1988
Dickey v. McNeal green
fladistctapp · 1984
1 sentence

1988We find several instances in which the appellate courts of this state have refused to give legal significance to a defendant's pro se speedy trial demand under Rule 3.191, Florida Rules of Criminal Procedure, thereby implicating the time requirements of that rule, when the defendant was otherwise represented by counsel. [1] See, Beverly v. State, 516 So.2d 30 (Fla. 1st DCA 1987); Carter v. State, 509 So.2d 1126 (Fla. 5th DCA 1987); and Dickey v. McNeal, 445 So.2d 692 (Fla. 5th DCA 1984).

11988–1988
Black v. Blue Ribbon Laundry green
fla · 1964
1 sentence

1964The statement is made: “The 90-day provision is mandatory in the sense that once that period has run, absent application upon good cause shown for extension, the cause must be determined by the deputy on the evidence which has been submitted.” Even though the 90-day period has lapsed without such application, extensions may be granted if the time requirements of the rule are waived either expressly or by “a state of facts upon which the determination of the presence of a waiver could be made.” Black v. Blue Ribbon Laundry, Fla., 161 So.2d 532 , opinion (Thornal, J.) ; Heath v. Thomas Lbr.

11964–1964
Heath v. Thomas Lumber Co. neutral
fla · 1962
1 sentence

1964Co., Fla. 1962, 140 So.2d 865, 866 .

11964–1964

Where else courts name it

FL 13 (1964–2023) ID 2 (2024–2025) AZ 2 (1992–2016)

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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