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

52 Florida opinions name it 2 courts 1924–2021 1 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 (25)

CaseFollowedCited
Kent v. Sutkergreen
fla · 1949 · cited in 5 Florida opinions naming this issue, 1976–2016
2 sentences

2016See id. at 433 (recognizing “that a ‘purely technical,’ non-merits judgment ‘may not be used as a basis for the operation of the doctrine of res judicata’ ” (quoting Kent v. Sutker, 40 So.2d 145, 147 (Fla.1949))).

2013In contrast, we have recognized that a “purely technical,” non-merits judgment “may not be used as a basis for the operation of the doctrine of res judicata.” Kent v. Sutker, 40 So.2d 145, 147 (Fla.1949). 8 The Engle judgment was a final judgment on the merits because it resolved substantive elements of the class’s claims against the Engle defendants.

45
Philip Morris USA, Inc. v. Douglasgreen
fla · 2013 · cited in 2 Florida opinions naming this issue, 2013–2016
2 sentences

2016See id. at 433 (recognizing “that a ‘purely technical,’ non-merits judgment ‘may not be used as a basis for the operation of the doctrine of res judicata’ ” (quoting Kent v. Sutker, 40 So.2d 145, 147 (Fla.1949))).

2013See id. at 433 (recognizing “that a ‘purely technical,’ non-merits judgment ‘may not be used as a basis for the operation of the doctrine of res judicata’ ” (quoting Kent v. Sutker, 40 So.2d 145, 147 (Fla.1949))); McCormack v. Abbott Labs., 617 F.Supp. 1521, 1524 (D.Mass.1985) (specifically noting that following decertification of a class action, individual plaintiffs are “bound by all rulings of substantive law” (emphasis added)).

22
State St. Bank and Trust Co. v. Badragreen
fladistctapp · 2000 · cited in 2 Florida opinions naming this issue, 2015–2015
2 sentences

2015Bank & Trust Co. v. Badra, 765 So.2d 251, 254 (Fla. 4th DCA 2000) (“A judgment rendered on any grounds which do not involve the merits of the action may not be used as the basis for the operation of the doctrine of res judica-ta.”).

2015Bank & Trust Co. v. Badra, 765 So.2d 251, 254 (Fla. 4th DCA 2000) (“A judgment rendered on any grounds which do not involve the.merits of the action may not be used as the basis for the operation of the doctrine of res judica-ta.”).

22
Allbright v. Hanftgreen
fladistctapp · 1976 · cited in 2 Florida opinions naming this issue, 2000–2002
2 sentences

2002See, e.g., Allbright v. Hanft, 333 So.2d 112, 114 (Fla. 2d DCA 1976) ("a judgment rendered on any grounds which do not involve the merits of the action may not be used as the basis for the operation of the doctrine of res judicata"); § 120.56(3)(a), Fla. Stat. (2000) ("A substantially affected person may seek an *8 administrative determination of the invalidity of an existing rule at any time during the existence of the rule").

2000See Allbright v. Hanft, 333 So.2d 112, 114 (Fla. 2d DCA 1976).

22
Amendments to Florida Rules of Criminal Procedure re Sentencing Guidelinesgreen
fla · 1993 · cited in 2 Florida opinions naming this issue, 1995–1997
2 sentences

1997See Ch. 93^06, Laws of Fla. According to the supreme court: “Existing caselaw construing the application of sentencing guidelines that is in conflict with the provisions of this rule or the statement of purpose or the principles embodied by the 1994 sentencing guidelines set out in subsection 921.001(4) is superseded by the operation of this rule.” Amendments to Florida Rules of Criminal Procedure re Sentencing Guidelines, 628 So.2d 1084, 1089 (Fla.1993); see also Capers v. State, 670 So.2d 967, 970 (Fla. 1st DCA 1995), approved, 678 So.2d 330 (Fla.1996).

1995Amendments to Florida Rules of Criminal Procedure re Sentencing Guidelines, 628 So.2d 1084, 1089 (Fla.1993); Fla.R.Crim.P. 3.702(b). [7] We therefore conclude that the victim's vulnerability on account of age justifies upward departure for offenses committed after January 1, 1994, even in sentencing for an offense of which the victim's age is an element.

22
Noble v. Yorkegreen
fla · 1986 · cited in 2 Florida opinions naming this issue, 1986–2021
2 sentences

2021Id.; see also Noble v. Yorke, 490 So. 2d 29, 31 (Fla. 1986) (holding absent specific statutory provision, there is no rule of law which in general exempts statutory rights and defenses from the operation of the doctrine of equitable estoppel).

1986Recently, our supreme court in Noble v. Yorke, 490 So.2d 29 (Fla.1986), where the respondent was injured by a dog bite when she was told by the petitioner to disregard a “bad dog” sign displayed on the property, stated that: [Ajbsent specific statutory provision, there is no rule of law which in general exempts statutory rights and defenses from the operation of the doctrine of equitable estoppel.

12
McCormack v. Abbott Laboratoriesgreen
mad · 1985 · cited in 1 Florida opinions naming this issue, 2013–2013
1 sentence

2013See id. at 433 (recognizing “that a ‘purely technical,’ non-merits judgment ‘may not be used as a basis for the operation of the doctrine of res judicata’ ” (quoting Kent v. Sutker, 40 So.2d 145, 147 (Fla.1949))); McCormack v. Abbott Labs., 617 F.Supp. 1521, 1524 (D.Mass.1985) (specifically noting that following decertification of a class action, individual plaintiffs are “bound by all rulings of substantive law” (emphasis added)).

11
Fred McGilvray, Inc. v. Askewgreen
fla · 1976 · cited in 1 Florida opinions naming this issue, 2013–2013
1 sentence

2013Such an operation of a presumption within the framework of a motion for summary judgment is consistent with the way the Supreme Court applied a statutory presumption in Fred McGilvray, Inc. v. Askew, 340 So.2d 475, 479-80 (Fla.1976).

11
PacifiCare Health Systems, Inc. v. Bookgreen
scotus · 2003 · cited in 1 Florida opinions naming this issue, 2011–2011
1 sentence

2011See PacifiCare, 538 U.S. at 407, 123 S.Ct. 1531 (holding that courts should not speculate on how an arbitrator might rule “in a manner that casts [agreements’] enforceability into doubt,” and in such cases the proper course is to compel arbitration); Kristian v. Comcast Corp., 446 F.3d 25, 40 (1st Cir.2006) (interpreting PacifiCare to state that “[g]iven the presumption in favor of arbitration, a court should not foreclose the operation of that presumption by deciding that there is a question of arbitrability when there is the possibility that an arbitrator’s decision in the first instance wou

11
Reese v. Stategreen
fla · 1997 · cited in 1 Florida opinions naming this issue, 2011–2011
1 sentence

2011See Christopher v. State, 583 So.2d 642, 646 (Fla.1991); see also Reese v. State, 694 So.2d 678, 683 (Fla.1997).

11
Punsky v. Clay County Sheriff's Officegreen
fladistctapp · 2009 · cited in 1 Florida opinions naming this issue, 2011–2011
1 sentence

2011See Punsky v. Clay County Sheriffs Office, 18 So.3d 577, 583 (Fla. 1st DCA 2009).

11
cluster 794138green
ca1 · 2006 · cited in 1 Florida opinions naming this issue, 2011–2011
1 sentence

2011See PacifiCare, 538 U.S. at 407, 123 S.Ct. 1531 (holding that courts should not speculate on how an arbitrator might rule “in a manner that casts [agreements’] enforceability into doubt,” and in such cases the proper course is to compel arbitration); Kristian v. Comcast Corp., 446 F.3d 25, 40 (1st Cir.2006) (interpreting PacifiCare to state that “[g]iven the presumption in favor of arbitration, a court should not foreclose the operation of that presumption by deciding that there is a question of arbitrability when there is the possibility that an arbitrator’s decision in the first instance wou

11
Christopher v. Stategreen
fla · 1991 · cited in 1 Florida opinions naming this issue, 2011–2011
1 sentence

2011See Christopher v. State, 583 So.2d 642, 646 (Fla.1991); see also Reese v. State, 694 So.2d 678, 683 (Fla.1997).

11
Ramirez v. Stategreen
fla · 1999 · cited in 1 Florida opinions naming this issue, 2011–2011
1 sentence

2011In Ramirez v. State, 739 So.2d 568, 580 (Fla.1999), the Supreme Court described the operation of this rule: Codified at section 90.108, Florida Statutes (1995), the rule of completeness provides that “when a writing or recorded statement or part thereof is introduced by a party, an adverse party may require him or her at that time to introduce any other part or any other writing or recorded statement that in fairness ought to be considered contemporaneously.” This rule has been applied to verbal statements as well.

11
Amendments to the Florida Family Law Rules of Procedure (Rule 12.525)green
fla · 2005 · cited in 1 Florida opinions naming this issue, 2006–2006
1 sentence

2006See Amendments to the Florida Family Law Rules of Procedure (Rule 12.525), 897 So.2d 467 (Fla.2005).

11
Weit v. Rhodesgreen
fladistctapp · 1997 · cited in 1 Florida opinions naming this issue, 2004–2004
1 sentence

2004Spanos Enters., Inc., 348 So.2d 920, 922 (Fla. 2d DCA 1977); Weit v. Rhodes, 691 So.2d 1108, 1109 (Fla. 4th DCA 1997).

11
Cabinet Craft v. AG Spanos Enterprisesgreen
fladistctapp · 1977 · cited in 1 Florida opinions naming this issue, 2004–2004
1 sentence

2004Spanos Enters., Inc., 348 So.2d 920, 922 (Fla. 2d DCA 1977); Weit v. Rhodes, 691 So.2d 1108, 1109 (Fla. 4th DCA 1997).

11
United States v. Alperingreen
cand · 2001 · cited in 1 Florida opinions naming this issue, 2002–2002
11
Capers v. Stategreen
fla · 1996 · cited in 1 Florida opinions naming this issue, 1997–1997
11
Capers v. Stategreen
fladistctapp · 1995 · cited in 1 Florida opinions naming this issue, 1997–1997
11
Ivory v. Stategreen
fla · 1977 · cited in 1 Florida opinions naming this issue, 1985–1985
11
Colcord v. Florida Rock Industries, Inc.green
fladistctapp · 1977 · cited in 1 Florida opinions naming this issue, 1985–1985
11
Gordon v. WARREN HEATING & ACgreen
fladistctapp · 1976 · cited in 1 Florida opinions naming this issue, 1978–1978
11
State v. Williamsgreen
fladistctapp · 1973 · cited in 1 Florida opinions naming this issue, 1976–1976
11
Gillespie v. Stategreen
· 1952 · cited in 1 Florida opinions naming this issue, 1965–1965
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 (48)

CaseCitedYears
Fernandez v. Cohn green
fladistctapp · 2011
1 sentence

2016We most recently explained the operation of the rule in Fernandez v. Cohn, 54 So.3d 1040 (Fla. 3d DCA 2011).

12016–2016
Philip Morris USA, Inc. v. Hallgren green
fladistctapp · 2013
1 sentence

2016Hallgren, 124 So.3d at 357 .

12016–2016
Buckeye Check Cashing, Inc. v. Cardegna green
scotus · 2006
1 sentence

2011This rationale is consistent with that used by the United States Supreme Court in Buckeye, 546 U.S. at 448-49, 126 S.Ct. 1204 , to address the “conundrum” that a contract ultimately found to be unenforceable could be used to arbitrate a dispute: It is true, as respondents assert, that the Prima Paint[ 13 ] rule permits a court to enforce an arbitration agreement in a contract that the arbitrator later finds to be void.

12011–2011
Carnival Corp. v. Middleton green
fladistctapp · 2006
2 sentences

2010The Florida Supreme Court in Allie stated the general rule that “[u]n-der the federal scheme ... a dismissal on statute of limitations grounds is considered a dismissal on the merits by the operation of the rule [Federal Rule of Civil Procedure 41(b) ].” 503 So.2d at 1241 ; Carnival Corp. v. Middleton, 941 So.2d at 424-25 .

2010The Florida Supreme Court in Allie stated the general rule that "[u]nder the federal scheme ... a dismissal on statute of limitations grounds is considered a dismissal on the merits by the operation of the rule [Federal Rule of Civil Procedure 41(b)]." 503 So.2d at 1241 ; Carnival Corp. v. Middleton, 941 So.2d at 424-25 .

12010–2010
Allie v. Ionata green
fla · 1987
2 sentences

2010The Florida Supreme Court in Allie stated the general rule that “[u]n-der the federal scheme ... a dismissal on statute of limitations grounds is considered a dismissal on the merits by the operation of the rule [Federal Rule of Civil Procedure 41(b) ].” 503 So.2d at 1241 ; Carnival Corp. v. Middleton, 941 So.2d at 424-25 .

2010The Florida Supreme Court in Allie stated the general rule that "[u]nder the federal scheme ... a dismissal on statute of limitations grounds is considered a dismissal on the merits by the operation of the rule [Federal Rule of Civil Procedure 41(b)]." 503 So.2d at 1241 ; Carnival Corp. v. Middleton, 941 So.2d at 424-25 .

12010–2010
State v. Perkins green
fla · 1977
1 sentence

2005Ashe v. Swenson, 397 U.S. 436, 445 , 90 S.Ct. 1189 , 25 L.Ed.2d 469 (1970), and State v. Perkins, 349 So.2d 161 (Fla.1977), recognized the proper operation of the doctrine in the criminal context, while Standefer v. United States, 447 U.S. 10, 24 , 100 S.Ct. 1999 , 64 L.Ed.2d 689 (1980), acknowledged limitations of the application of the doctrine in criminal cases.

12005–2005
Ashe v. Swenson green
scotus · 1970
2 sentences

2005Ashe v. Swenson, 397 U.S. 436, 445 , 90 S.Ct. 1189 , 25 L.Ed.2d 469 (1970), and State v. Perkins, 349 So.2d 161 (Fla.1977), recognized the proper operation of the doctrine in the criminal context, while Standefer v. United States, 447 U.S. 10, 24 , 100 S.Ct. 1999 , 64 L.Ed.2d 689 (1980), acknowledged limitations of the application of the doctrine in criminal cases.

2005Ashe v. Swenson, 397 U.S. 436, 445 , 90 S.Ct. 1189 , 25 L.Ed.2d 469 (1970), and State v. Perkins, 349 So.2d 161 (Fla.1977), recognized the proper operation of the doctrine in the criminal context, while Standefer v. United States, 447 U.S. 10, 24 , 100 S.Ct. 1999 , 64 L.Ed.2d 689 (1980), acknowledged limitations of the application of the doctrine in criminal cases.

12005–2005
Standefer v. United States green
scotus · 1980
2 sentences

2005Ashe v. Swenson, 397 U.S. 436, 445 , 90 S.Ct. 1189 , 25 L.Ed.2d 469 (1970), and State v. Perkins, 349 So.2d 161 (Fla.1977), recognized the proper operation of the doctrine in the criminal context, while Standefer v. United States, 447 U.S. 10, 24 , 100 S.Ct. 1999 , 64 L.Ed.2d 689 (1980), acknowledged limitations of the application of the doctrine in criminal cases.

2005Ashe v. Swenson, 397 U.S. 436, 445 , 90 S.Ct. 1189 , 25 L.Ed.2d 469 (1970), and State v. Perkins, 349 So.2d 161 (Fla.1977), recognized the proper operation of the doctrine in the criminal context, while Standefer v. United States, 447 U.S. 10, 24 , 100 S.Ct. 1999 , 64 L.Ed.2d 689 (1980), acknowledged limitations of the application of the doctrine in criminal cases.

12005–2005
Burger v. State green
ga · 1977
2 sentences

2004E.g., Magar v. State, 308 Ark. 380 , 826 S.W.2d 221 (1992) (finding privilege inapplicable to defendant's admission to minister's accusation of sexual abuse of minors where conversation was initiated by minister for disciplinary purposes and not for spiritual counseling); Burger v. State, 238 Ga. 171 , 231 S.E.2d 769 (1977) (holding defendant could not claim privilege concerning conversational statements to clergy member who was his friend and frequent companion concerning defendant's intent to kill his wife and her lover); Keenan v. Gigante, 47 N.Y.2d 160 , 417 N.Y.S.2d 226 , 390 N.E.2d 1151

2004E.g., Magar v. State, 308 Ark. 380 , 826 S.W.2d 221 (1992) (finding privilege inapplicable to defendant's admission to minister's accusation of sexual abuse of minors where conversation was initiated by minister for disciplinary purposes and not for spiritual counseling); Burger v. State, 238 Ga. 171 , 231 S.E.2d 769 (1977) (holding defendant could not claim privilege concerning conversational statements to clergy member who was his friend and frequent companion concerning defendant's intent to kill his wife and her lover); Keenan v. Gigante, 47 N.Y.2d 160 , 417 N.Y.S.2d 226 , 390 N.E.2d 1151

12004–2004
Magar v. State green
ark · 1992
2 sentences

2004E.g., Magar v. State, 308 Ark. 380 , 826 S.W.2d 221 (1992) (finding privilege inapplicable to defendant's admission to minister's accusation of sexual abuse of minors where conversation was initiated by minister for disciplinary purposes and not for spiritual counseling); Burger v. State, 238 Ga. 171 , 231 S.E.2d 769 (1977) (holding defendant could not claim privilege concerning conversational statements to clergy member who was his friend and frequent companion concerning defendant's intent to kill his wife and her lover); Keenan v. Gigante, 47 N.Y.2d 160 , 417 N.Y.S.2d 226 , 390 N.E.2d 1151

2004E.g., Magar v. State, 308 Ark. 380 , 826 S.W.2d 221 (1992) (finding privilege inapplicable to defendant's admission to minister's accusation of sexual abuse of minors where conversation was initiated by minister for disciplinary purposes and not for spiritual counseling); Burger v. State, 238 Ga. 171 , 231 S.E.2d 769 (1977) (holding defendant could not claim privilege concerning conversational statements to clergy member who was his friend and frequent companion concerning defendant's intent to kill his wife and her lover); Keenan v. Gigante, 47 N.Y.2d 160 , 417 N.Y.S.2d 226 , 390 N.E.2d 1151

12004–2004
Keenan v. Gigante green
ny · 1979
2 sentences

2004E.g., Magar v. State, 308 Ark. 380 , 826 S.W.2d 221 (1992) (finding privilege inapplicable to defendant's admission to minister's accusation of sexual abuse of minors where conversation was initiated by minister for disciplinary purposes and not for spiritual counseling); Burger v. State, 238 Ga. 171 , 231 S.E.2d 769 (1977) (holding defendant could not claim privilege concerning conversational statements to clergy member who was his friend and frequent companion concerning defendant's intent to kill his wife and her lover); Keenan v. Gigante, 47 N.Y.2d 160 , 417 N.Y.S.2d 226 , 390 N.E.2d 1151

2004E.g., Magar v. State, 308 Ark. 380 , 826 S.W.2d 221 (1992) (finding privilege inapplicable to defendant's admission to minister's accusation of sexual abuse of minors where conversation was initiated by minister for disciplinary purposes and not for spiritual counseling); Burger v. State, 238 Ga. 171 , 231 S.E.2d 769 (1977) (holding defendant could not claim privilege concerning conversational statements to clergy member who was his friend and frequent companion concerning defendant's intent to kill his wife and her lover); Keenan v. Gigante, 47 N.Y.2d 160 , 417 N.Y.S.2d 226 , 390 N.E.2d 1151

12004–2004
In Re Grand Jury Proceedings (Violette) green
ca1 · 1999
1 sentence

2002Id. at 74 ; see also United States v. Alperin, 128 F.Supp.2d 1251 (N.D.Cal.2001)(" Jaffee does not discuss how the privilege is to be applied when a criminal defendant's constitutional rights are implicated."); 3 JACK B.

12002–2002
Scott v. State green
fla · 2002
1 sentence

2002A close reading of Medlin and Chicone , however, yields the inescapable conclusion that the presumption of knowledge applies only to cases of actual possession, and we said as much in Chicone .... 808 So.2d at 171 .

12002–2002
Johnson v. Feder green
fla · 1986
11993–1993
McShay v. State neutral
fladistctapp · 1984
11993–1993
Balsam v. DEPT. OF HEALTH & REHAB. SERVICES green
fladistctapp · 1984
11992–1992
City of Miami Beach v. Mr. Samuel's, Inc. green
fla · 1977
11988–1988
Burritt v. Harris green
fla · 1965
11984–1984
Childers v. State green
fladistctapp · 1973
11983–1983
Paley v. Cocoa Masonry, Inc. green
fladistctapp · 1978
11980–1980
State v. Kurtz green
fladistctapp · 1978
11980–1980
Indian Towing Co. v. United States green
scotus · 1955
11979–1979
Frazier v. State green
fladistctapp · 1976
11979–1979
Hardison v. State green
fladistctapp · 1977
11979–1979
Breedlove v. State neutral
fladistctapp · 1974
11979–1979
Rowan v. State green
fladistctapp · 1971
11979–1979
Bank of Augusta v. Earle green
· 1839
11978–1978
Lake v. Hancock ex rel. Payne green
fla · 1896
11976–1976
Southern Gulf Utilities, Inc. v. Boca Ciega Sanitary District green
fladistctapp · 1970
11975–1975
Lego v. Twomey green
scotus · 1972
11974–1974
Louisville & Nashville Railroad v. Yniestra neutral
fla · 1886
11973–1973
City of Coral Gables v. Baljet green
fladistctapp · 1971
11972–1972
Holl v. Talcott green
fla · 1966
11968–1968
West v. State green
fla · 1942
11965–1965
Spencer v. State green
fla · 1961
11965–1965
National Surety Corp. v. Windham green
fla · 1954
11965–1965
Wawner v. Sellic Stone Studio green
fla · 1954
11960–1960
City of Tampa v. Easton green
fla · 1940
11943–1943
Scott v. City of Tampa neutral
fla · 1911
11943–1943
Tomasello Cocoa Bank & Trust Co. v. Nisbet green
fla · 1933
11938–1938

Statutes the citing opinions construe

FL § 120.54 (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

CA 154 (1857–2025) NY 132 (1823–2024) PA 89 (1834–2020) IL 86 (1864–2023) TX 84 (1860–2024) AL 77 (1846–2018) NC 59 (1855–2025) CT 57 (1874–2022) FL 52 (1924–2021) MD 50 (1873–2023) MO 46 (1879–2003) IA 46 (1864–2018) IN 39 (1833–2020) NJ 37 (1903–2002) WA 37 (1890–2017) NE 37 (1883–2017) MA 31 (1894–2014) CO 29 (1890–2020) OK 26 (1896–2012) NM 24 (1924–2010) KS 23 (1888–2013) OR 23 (1900–2017) OH 22 (1907–2019) GA 21 (1909–2020) VA 21 (1874–2023) KY 20 (1883–1997) MI 19 (1851–2025) AR 18 (1915–2003) WV 16 (1907–2016) MN 16 (1877–2019) AZ 16 (1934–2008) WI 14 (1894–2020) MS 14 (1875–2014) WY 13 (1899–2019) TN 13 (1906–2014) LA 11 (1860–2010) UT 10 (1987–2024) DC 10 (1914–2019) DE 8 (1880–2016) MT 7 (1923–1999) RI 6 (1873–2004) ID 6 (1918–1997) SD 5 (1897–2022) ND 5 (1976–1996) NH 5 (1853–1994) AK 5 (1967–1983) NV 5 (1867–1936) SC 4 (1879–1969) ME 4 (1897–1983) HI 4 (1958–1987)

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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