motion to dismiss rule (Florida) · Go Syfert
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motion to dismiss rule in Florida

52 Florida opinions name it 2 courts 1934–2026 8 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 (36)

CaseFollowedCited
Nicholas A. James v. Daniel K. Leigh, and Kenny Leigh, P.A.green
fladistctapp · 2014 · cited in 4 Florida opinions naming this issue, 2019–2024
2 sentences

2024“When the trial court denies a motion to dismiss on immunity grounds, certiorari review . . . is proper because absolute immunity protects a party from having to defend a lawsuit at all and waiting until final appeal would render such immunity meaningless if the lower court denied dismissal in error.” James v. Leigh, 145 So. 3d 1006, 1008 (Fla. 1st DCA 2014); see also Bank of N.Y.

2023James v. Leigh, 145 So. 3d 1006, 1008 (Fla. 1st DCA 2014) (“When the trial court denies a motion to dismiss on immunity grounds, certiorari review of the non-final order is proper because absolute immunity protects a party from having to defend a lawsuit at all and waiting until final appeal would render such immunity meaningless if the lower court denied dismissal in error.”).

44
State v. Paskogreen
fladistctapp · 2002 · cited in 2 Florida opinions naming this issue, 2016–2016
2 sentences

2016State v. Pasko, 815 So. 2d 680, 681 (Fla. 2d DCA 2002).

2016State v. Pasko, 815 So.2d 680, 681 (Fla. 2d DCA 2002).

22
Martin-Johnson, Inc. v. Savagegreen
fla · 1987 · cited in 2 Florida opinions naming this issue, 1997–2016
2 sentences

2016Martin -Johnson, Inc. v. Savage, 509 So.2d 1097, 1098-99 , 1098 n. 1 (Fla.1987) (holding that certiorari is not a proper vehicle for reviewing a denial of a motion to strike a claim for punitive damages, notwithstanding that such a claim can serve as a basis for; an inquiry into protected matters). ■ Consequently, although we might quarrel with the'trial court’s determination that Florida’s independent tort rule is not a bar to Berezovsky’s punitive damage claim, our limited certiorari jurisdiction prevents us from quashing the trial court’s order on this basis.

1997See Martin-Johnson, Inc. v. Savage, 509 So.2d 1097 (Fla.1987); Thompson v. Thompson, 635 So.2d 1064 (Fla. 5th DCA 1994).

12
Foster v. Chunggreen
fladistctapp · 1999 · cited in 1 Florida opinions naming this issue, 2025–2025
1 sentence

2025See Foster v. Chung, 738 So. 2d 350 , 352 (Fla. 4th DCA 1999) (remanding “for a determination of whether [the trial court] would grant [the plaintiff] an extension to serve [the defendant] or dismiss the action in light of rule 1.070(j) as amended”).

11
Quality Holdings of Florida, Inc. v. Selective Investments, IV, LLCgreen
fladistctapp · 2009 · cited in 1 Florida opinions naming this issue, 2025–2025
1 sentence

2025We reject the Association’s argument that the lack of a transcript for the motion to dismiss hearing requires affirmance. “[A]n appellate court may reverse an order even in the absence of an adequate record if the order 10 is fundamentally erroneous on its face.” Quality Holdings of Fla., Inc. v. Selective Invs., IV, LLC, 25 So. 3d 34, 36 (Fla. 4th DCA 2009).

11
State v. Kalogeropolousgreen
fla · 2000 · cited in 1 Florida opinions naming this issue, 2022–2022
1 sentence

2022See, e.g., State v. Kalogeropolous, 758 So. 2d 110, 111 (Fla. 2000).

11
LoBiondo v. Schwartzgreen
nj · 2009 · cited in 1 Florida opinions naming this issue, 2019–2019
1 sentence

2019Bd. of Trs. v. Monk, 68 So. 3d 316, 318 (Fla. 1st DCA 2011))); see also LoBiondo v. Schwartz, 970 A.2d 1007, 1020 (N.J. 2009) (discussing the two categories of anti-SLAPP statutes and citing Florida's as within the category that "include[s] a legislative declaration that a public participant who has exercised his or her free speech right, sometimes in statutorily defined manner, enjoys immunity").

11
HSBC Bank USA, Nat'l Ass'n v. Nelsongreen
fladistctapp · 2018 · cited in 1 Florida opinions naming this issue, 2019–2019
1 sentence

2019See, e.g., HSBC Bank USA, Nat'l Ass'n v. Nelson, 246 So. 3d 486, 489 (Fla. 2d DCA 2018).

11
Florida State University Board of Trustees v. Monkgreen
fladistctapp · 2011 · cited in 1 Florida opinions naming this issue, 2019–2019
1 sentence

2019Bd. of Trs. v. Monk, 68 So. 3d 316, 318 (Fla. 1st DCA 2011))); see also LoBiondo v. Schwartz, 970 A.2d 1007, 1020 (N.J. 2009) (discussing the two categories of anti-SLAPP statutes and citing Florida's as within the category that "include[s] a legislative declaration that a public participant who has exercised his or her free speech right, sometimes in statutorily defined manner, enjoys immunity").

11
Hudson v. Stategreen
fladistctapp · 1999 · cited in 1 Florida opinions naming this issue, 2019–2019
1 sentence

2019See Hudson v. State, 745 So. 2d 997, 999 (Fla. 2d DCA 1999).

11
Dent v. Belingreen
fladistctapp · 1986 · cited in 1 Florida opinions naming this issue, 2018–2018
1 sentence

2018See id. (finding a party is entitled to a declaration when that party pleads the necessary factual allegations for each element of a declaratory judgment claim).

11
Houk v. PennyMac Corp.green
fladistctapp · 2017 · cited in 1 Florida opinions naming this issue, 2017–2017
1 sentence

2017See Houk v. PennyMac Corp., 210 So. 3d 726, 730-31 (Fla. 2d DCA 2017); Fish Tale Sales & Serv., Inc. v. Nice, 106 So. 3d 57, 63 (Fla. 2d DCA 2013). -4- " 'Waiver' has been defined 'as the voluntary and intentional relinquishment of a known right or conduct which implies the voluntary and intentional relinquishment of a known right.' " Green Tree Servicing, LLC, 15 So. 3d at 687 (quoting Raymond James Fin.

11
Fish Tale Sales & Service, Inc. v. Nicegreen
fladistctapp · 2013 · cited in 1 Florida opinions naming this issue, 2017–2017
1 sentence

2017See Houk v. PennyMac Corp., 210 So. 3d 726, 730-31 (Fla. 2d DCA 2017); Fish Tale Sales & Serv., Inc. v. Nice, 106 So. 3d 57, 63 (Fla. 2d DCA 2013). -4- " 'Waiver' has been defined 'as the voluntary and intentional relinquishment of a known right or conduct which implies the voluntary and intentional relinquishment of a known right.' " Green Tree Servicing, LLC, 15 So. 3d at 687 (quoting Raymond James Fin.

11
Joseph v. Stategreen
fladistctapp · 2012 · cited in 1 Florida opinions naming this issue, 2017–2017
2 sentences

2017The State gave notice of appeal. • Appellate Analysis In a motion to dismiss for immunity under section 776.032, Florida Statutes, “[t]he trial court’s factual findings are entitled to deference and must be supported by competent substantial evidence.” Joseph v. State, 103 So.3d 227, 220 (Fla. 4th DCA 2012).

2017“The trial court’s legal conclusions are reviewed de novo.” Id. at 230 .

11
Styron v. Stategreen
fladistctapp · 1995 · cited in 1 Florida opinions naming this issue, 2015–2015
2 sentences

2015See Styron v. State, 662 So.2d 965, 966 (Fla. 1st DCA 1995).

2015See Styron v. State, 662 So. 2d 965, 966 (Fla. 1st DCA 1995).

11
Gee v. Stategreen
fladistctapp · 2009 · cited in 1 Florida opinions naming this issue, 2014–2014
1 sentence

2014See Gee v. State, 13 So.3d 68, 69 (Fla. 1st DCA 2009) (reversing summary denial where the movant alleged that counsel twice failed to file a notice of expiration of speedy trial time prior to moving for dismissal on speedy trial grounds, as required by Florida Rule of Criminal Procedure 3.191, and the trial judge expressed doubt about finding a jury during the rule 3.191 recapture window but denied the motion to dismiss because defense counsel had failed to follow the proper procedure).

11
Lonestar Alternative Solution, Inc. v. Leview-Boymelgreen Soleil Developers, LLCgreen
fladistctapp · 2009 · cited in 1 Florida opinions naming this issue, 2010–2010
1 sentence

2010Solution, Inc. v. Leview-Boymelgreen Soleil Developers, LLC., 10 So.3d 1169, 1171 (Fla. 3d DCA 2009) (citing Meadows Cmty. Ass’n v. Russell-Tutty, 928 So.2d 1276, 1280 (Fla. 2d DCA 2006)).

11
MEADOWS COMMUNITY ASS'N v. Russell-Tuttygreen
fladistctapp · 2006 · cited in 1 Florida opinions naming this issue, 2010–2010
11
Gee v. Stategreen
fladistctapp · 2007 · cited in 1 Florida opinions naming this issue, 2009–2009
11
People v. Guenthergreen
colo · 1987 · cited in 1 Florida opinions naming this issue, 2009–2009
11
State v. Lebrongreen
fladistctapp · 2007 · cited in 1 Florida opinions naming this issue, 2008–2008
11
Miami-Dade County v. Fentegreen
fladistctapp · 2007 · cited in 1 Florida opinions naming this issue, 2007–2007
11
Koehler v. Merrill Lynch & Co., Inc.green
fladistctapp · 1998 · cited in 1 Florida opinions naming this issue, 2007–2007
11
Jenne v. Marantogreen
fladistctapp · 2002 · cited in 1 Florida opinions naming this issue, 2007–2007
11
Wilcox v. Morsegreen
fladistctapp · 1997 · cited in 1 Florida opinions naming this issue, 1999–1999
11
Smith v. Broward Countygreen
fladistctapp · 1995 · cited in 1 Florida opinions naming this issue, 1999–1999
11
Heinz v. Watsongreen
fladistctapp · 1993 · cited in 1 Florida opinions naming this issue, 1999–1999
11
Gelb v. Mirandagreen
fladistctapp · 1984 · cited in 1 Florida opinions naming this issue, 1999–1999
11
Pizzi v. Central Bank and Trust Companygreen
fla · 1971 · cited in 1 Florida opinions naming this issue, 1998–1998
11
Mobil Oil Corp. v. Dade County Esoil Management Co.green
flsd · 1997 · cited in 1 Florida opinions naming this issue, 1998–1998
11
Khandjian v. Compagnie Financiere Mediterranee Cofimed, SAgreen
fladistctapp · 1993 · cited in 1 Florida opinions naming this issue, 1995–1995
11
State v. Feaglegreen
fladistctapp · 1992 · cited in 1 Florida opinions naming this issue, 1993–1993
11
Brown v. Browngreen
fladistctapp · 1986 · cited in 1 Florida opinions naming this issue, 1990–1990
11
Brown v. Montgomery Ward & Companygreen
fladistctapp · 1971 · cited in 1 Florida opinions naming this issue, 1990–1990
11
Adams Engineering Co. v. Construction Products Corp.green
fla · 1963 · cited in 1 Florida opinions naming this issue, 1985–1985
11
State v. Smithgreen
fladistctapp · 1977 · cited in 1 Florida opinions naming this issue, 1983–1983
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 (43)

CaseCitedYears
Hillman Const. Corp. v. Wainer green
fladistctapp · 1994
2 sentences

2010Hillman Const. Corp. v. Wainer, 636 So.2d 576 (Fla. 4th DCA 1994).

1996Hillman Const Corp. v. Wainer, 636 So.2d 576 (Fla. 4th DCA 1994).

21996–2010
Del Duca v. Anthony green
fla · 1991
2 sentences

2005Anthony, 557 So.2d at 658-59, approved by, Del Duca, 587 So.2d at 1308-09 .

2002Anthony, 557 So.2d at 658-59 , approved by, Del Duca, 587 So.2d at 1308-09 . *977 "First, the defendant is required to show there has been no record activity for the year preceding the motion.

22002–2005
State v. West green
fladistctapp · 1972
2 sentences

1993“Intent is not an issue to be decided on a motion to dismiss under rule 3.190(c)(4), Florida Rules of Criminal Procedure, since intent is usually inferred from the acts of the parties and the surrounding circumstances; being a state of mind, intent is a question of fact to be determined by the trier of fact, who has the opportunity to observe all of the witnesses.” J.T.S. at 419, citing State v. West, 262 So.2d 457 (Fla. 4th DCA1972).

1983State v. Evans, 394 So.2d 1068 (Fla. 4th DCA 1981); State v. Rogers, 386 So.2d 278 (Fla. 2d DCA), petition for review denied, 392 So.2d 1378 (Fla. 1980); Cummings v. State, 378 So.2d 879 (Fla. 1st DCA 1979), cert. denied, 386 So.2d 635 (Fla. 1980); State v. J.T.S., 373 So.2d 418 (Fla. 2d DCA 1979); State v. West, 262 So.2d 457 (Fla. 4th DCA 1972).

21983–1993
Applegate v. Barnett Bank of Tallahassee green
fla · 1979
1 sentence

2026That said, Greenbox contends we should affirm because we do not have a transcript of the motion to dismiss hearing, citing Applegate v. Barnett Bank of Tallahassee, 377 So. 2d 1150 (Fla.1979).

12026–2026
United Automobile Insurance Co. v. Law Offices of Libman green
fladistctapp · 2010
1 sentence

2021Libman, 46 So. 3d 1101 , 1103–04 (Fla. 3d DCA 2010) (“A motion to dismiss under rule 1.140(b) tests whether the plaintiff has stated a cause of action, not whether the plaintiff will prevail at trial.

12021–2021
NORMAN GUNDEL v. AV HOMES, INC. AND AVATAR PROPERTIES, INC. green
fladistctapp · 2019
2 sentences

2021In the order on appeal, the trial court concluded that Plaintiffs’ argument that the ordinary motion to dismiss standard applied contravened the plain language, not of the statute, but of Gundel v. AV Homes, Inc., 264 So. 3d 304 (Fla. 2d DCA 2019). 4 In Gundel, the Second District discussed the dismissal standard applicable under Florida’s Anti-SLAPP statute.

2021The court recognized, as we have, that “the statute is silent as to the burden or procedure for considering a motion to dismiss.” Id. at 314 .

12021–2021
Mobley v. State green
fladistctapp · 2016
1 sentence

2018Canchola thereafter filed a motion to dismiss violation of probation for lack of subject matter jurisdiction, relying on section 948.06(1)(f), Florida Statutes (2015), and Mobley v. State, 197 So. 3d 572 (Fla. 4th DCA 2016).

12018–2018
Green Tree Servicing, LLC v. McLeod green
fladistctapp · 2009
1 sentence

2017See Houk v. PennyMac Corp., 210 So. 3d 726, 730-31 (Fla. 2d DCA 2017); Fish Tale Sales & Serv., Inc. v. Nice, 106 So. 3d 57, 63 (Fla. 2d DCA 2013). -4- " 'Waiver' has been defined 'as the voluntary and intentional relinquishment of a known right or conduct which implies the voluntary and intentional relinquishment of a known right.' " Green Tree Servicing, LLC, 15 So. 3d at 687 (quoting Raymond James Fin.

12017–2017
Globe Newspaper Co. v. King green
fla · 1995
1 sentence

2016Globe Newspaper Co., 658 So.2d at 519-20 . ■Although in Club Eden Roc, Inc. v. Fortune Cookie Restaurant, Inc., 490 So.2d 210 (Fla. 3d DCA 1986), this Court-enter-, tained a petition for certiorari to review-an order denying a motion to dismiss a claim for punitive damages based on Florida’s independent tort rule, this decision predates both section 768.72 and the Florida Supreme Court’s determination that cer-tiorari jurisdiction is reserved for "orders granting leave to.plead punitive damages *520 claims when the trial court has failed to comply with the statute’s procedural requirements.

12016–2016
Flea Market, USA, Inc. v. Cohen green
fladistctapp · 1986
1 sentence

2016Globe Newspaper Co., 658 So.2d at 519-20 . ■Although in Club Eden Roc, Inc. v. Fortune Cookie Restaurant, Inc., 490 So.2d 210 (Fla. 3d DCA 1986), this Court-enter-, tained a petition for certiorari to review-an order denying a motion to dismiss a claim for punitive damages based on Florida’s independent tort rule, this decision predates both section 768.72 and the Florida Supreme Court’s determination that cer-tiorari jurisdiction is reserved for "orders granting leave to.plead punitive damages *520 claims when the trial court has failed to comply with the statute’s procedural requirements.

12016–2016
Govoni v. State neutral
fladistctapp · 2009
2 sentences

2015As then-Chief Judge Gross explained in his special concurrence in Govoni v. State, 17 So.3d 809 (Fla. 4th DCA 2009), quashed, 67 So.3d 1048 (Fla.2011), the procedure set forth in rule 3.190(b) is well-suited for motions to dismiss based on statutory immunity and is consistent with jurisprudence that requires the defendant, who is seeldng the immunity, to bear the burden of proof by a preponderance of the evidence: A motion to dismiss under rule 3.190(c)(4) is not well-suited to resolve a claim of “true immunity” from prosecution.

2015As then-Chief Judge Gross explained in his special concurrence in Govoni v. State, 17 So. 3d 809 (Fla. 4th DCA 2009), quashed, 67 So. 3d 1048 (Fla. 2011), the procedure set forth in rule 3.190(b) is well-suited for motions to dismiss based on statutory immunity and is consistent with jurisprudence that requires the defendant, who is seeking the immunity, to bear the burden of proof by a preponderance of the evidence: A motion to dismiss under rule 3.190(c)(4) is not well-suited to resolve a claim of “true immunity” from prosecution.

12015–2015
Govoni v. State neutral
fla · 2011
2 sentences

2015As then-Chief Judge Gross explained in his special concurrence in Govoni v. State, 17 So.3d 809 (Fla. 4th DCA 2009), quashed, 67 So.3d 1048 (Fla.2011), the procedure set forth in rule 3.190(b) is well-suited for motions to dismiss based on statutory immunity and is consistent with jurisprudence that requires the defendant, who is seeldng the immunity, to bear the burden of proof by a preponderance of the evidence: A motion to dismiss under rule 3.190(c)(4) is not well-suited to resolve a claim of “true immunity” from prosecution.

2015As then-Chief Judge Gross explained in his special concurrence in Govoni v. State, 17 So. 3d 809 (Fla. 4th DCA 2009), quashed, 67 So. 3d 1048 (Fla. 2011), the procedure set forth in rule 3.190(b) is well-suited for motions to dismiss based on statutory immunity and is consistent with jurisprudence that requires the defendant, who is seeking the immunity, to bear the burden of proof by a preponderance of the evidence: A motion to dismiss under rule 3.190(c)(4) is not well-suited to resolve a claim of “true immunity” from prosecution.

12015–2015
Estate of Rocks v. McLaughlin Engineering Co. green
fladistctapp · 2010
1 sentence

2014There, we held that “[t]he test for a motion to dismiss under rule 1.140(b)(6) [for failure to state a cause of action] is whether the pleader could prove any set of facts whatever in support of the claim.” Id. at 826 .

12014–2014
XL Specialty Ins. Co. v. Skystream, Inc. green
fladistctapp · 2008
12009–2009
LEMAY v. State neutral
fla · 2007
12008–2008
State v. Fordham green
fladistctapp · 1985
12004–2004
Anthony v. Schmitt green
fladistctapp · 1990
12002–2002
America Online, Inc. v. GreatDeals. Net green
vaed · 1999
12000–2000
Thompson v. Thompson green
fladistctapp · 1994
11997–1997
Grooms v. Garcia green
fladistctapp · 1985
11997–1997
State v. O'BRIEN green
fladistctapp · 1994
11995–1995
State v. Booker green
fladistctapp · 1988
11993–1993
State v. Stenza green
fladistctapp · 1984
11993–1993
State v. Milton green
fladistctapp · 1986
11993–1993
In re Albert green
scotus · 1986
11993–1993
Carter v. United States green
scotus · 1986
11993–1993
Fleming v. Moore green
scotus · 1986
11993–1993
State v. Hricik green
fladistctapp · 1984
11993–1993
Cruz v. State green
fla · 1985
11991–1991
City of Miami Beach v. Smith green
fla · 1971
11990–1990
Jerry Chapman, Inc. v. Ivey green
fladistctapp · 1984
11985–1985
Thomas v. PERSONAL REP. OF ESTATE OF DeLOACH green
fladistctapp · 1981
11985–1985
Smith v. State green
fladistctapp · 1975
11983–1983
State v. Hicks green
fla · 1982
11983–1983
State v. JTS green
fladistctapp · 1979
11983–1983
Cummings v. State green
fladistctapp · 1979
11983–1983
State v. Evans green
fladistctapp · 1981
11983–1983
Hicks v. State green
fladistctapp · 1981
11983–1983
State v. Rogers green
fladistctapp · 1980
11983–1983
State v. Swoveland green
fladistctapp · 1982
11983–1983

Statutes the citing opinions construe

FL § 776.032 (3)

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

NY 101 (1899–2026) TX 61 (2001–2023) MA 56 (1977–2026) FL 52 (1934–2026) IL 35 (1948–2026) OH 30 (1936–2026) GA 27 (1912–2025) UT 27 (1993–2026) NC 25 (1986–2023) MO 24 (1968–2025) IA 18 (1975–2022) ME 18 (1999–2023) MD 17 (1989–2026) OR 12 (1988–2026) NM 11 (1970–2019) MS 10 (1994–2024) WA 9 (2006–2020) CO 9 (2002–2026) MT 8 (2007–2016) OK 8 (1997–2023) MN 8 (1989–2025) SC 8 (1941–2022) AL 8 (1983–2026) DE 8 (2014–2026) AR 6 (1998–2019) CA 6 (2008–2024) NJ 6 (1955–2026) IN 6 (1972–2019) CT 6 (1992–2019) AZ 6 (1976–2023) HI 5 (1993–2017) NV 4 (1993–2025) MI 4 (1985–2017) NE 4 (1988–2013) WY 4 (2013–2026) WI 4 (2006–2024) WV 3 (2015–2020) KY 3 (1974–2026) VT 3 (1925–2024) KS 3 (2012–2021) DC 2 (1995–2009) SD 2 (1988–2009) PA 2 (2018–2024) TN 2 (1998–2015)

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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