Florida Statute 48.194 - Full Text and Legal Analysis

The 2025 Florida Statutes

Title VI
CIVIL PRACTICE AND PROCEDURE

Chapter 48
PROCESS AND SERVICE OF PROCESS

View Entire Chapter

F.S. 48.194

48.194 Personal service in another state, territory, or commonwealth of the United States.—

¹(1) Except as otherwise provided herein, service of process on a party in another state, territory, or commonwealth of the United States must be made in the same manner as service within this state by any person authorized to serve process in the state where service shall be made. No order of court is required. A return-of-service form described in s. 48.21, or any other competent evidence, must be filed with the court stating the time, manner, and place of service. The court may consider such evidence in determining whether service has been properly made.

¹(2) When in rem or quasi in rem relief is sought in a foreclosure proceeding as defined by s. 702.09, and the address of the person to be served is known, service of process on a person in another state, territory, or commonwealth of the United States may be made by registered mail as follows:

(a) The party’s attorney or the party, if the party is not represented by an attorney, shall place a copy of the original process and the complaint, petition, or other initial pleading or paper and, if applicable, the order to show cause issued pursuant to s. 702.10 in a sealed envelope with adequate postage addressed to the person to be served.

(b) The envelope must be placed in the mail as registered mail.

(c) Service under this subsection is deemed obtained upon the signing of the return receipt by the person allowed to be served by law.

(3) If the registered mail which is sent as provided for in subsection (2) is returned with an endorsement or stamp showing “refused,” the party’s attorney or the party, if the party is not represented by an attorney, may serve original process by first-class mail. The failure to claim registered mail is not refusal of service within the meaning of this subsection. Service of process pursuant to this subsection shall be perfected as follows:

(b) The envelope shall be mailed by first-class mail with the return address of the party’s attorney or the party, if the party is not represented by an attorney, on the envelope.

(4) If service of process is obtained under subsection (2), the party’s attorney or the party, if the party is not represented by an attorney, shall file an affidavit setting forth the return of service. The affidavit shall state the nature of the process; the date on which the process was mailed by registered mail; the name and address on the envelope containing the process; the fact that the process was mailed registered mail return receipt requested; who signed the return receipt, if known, and the basis for that knowledge; and the relationship between the person who signed the receipt and the person to be served, if known, and the basis for that knowledge. The return receipt from the registered mail shall be attached to the affidavit. If service of process is perfected under subsection (3), the party’s attorney or the party, if the party is not represented by an attorney, shall file an affidavit setting forth the return of service. The affidavit shall state the nature of the process; the date on which the process was mailed by registered mail; the name and address on the envelope containing the process that was mailed by registered mail; the fact that the process was mailed registered mail and was returned with the endorsement or stamp “refused”; the date, if known, the process was “refused”; the date on which the process was mailed by first-class mail; the name and address on the envelope containing the process that was mailed by first-class mail; and the fact that the process was mailed by first-class mail with a return address of the party or the party’s attorney on the envelope. The return envelope from the attempt to mail process by registered mail and the return envelope, if any, from the attempt to mail the envelope by first-class mail shall be attached to the affidavit.

History.—s. 1, ch. 73-179; s. 4, ch. 93-250; s. 7, ch. 97-278; s. 6, ch. 2019-67; s. 14, ch. 2022-190.

¹Note.—Section 5, ch. 2025-13, provides:

“(1) The amendments made to chapter 48, Florida Statutes, by chapter 2022-190, Laws of Florida, apply to causes of action that accrued on or after January 2, 2023, and to all causes of action that accrued before January 2, 2023, for which service of process was effectuated on or after January 2, 2023.

“(2) Notwithstanding subsection (1), any service of process that occurred between January 2, 2023, and October 1, 2025, which has not been invalidated by a court, is valid if such service complied with either chapter 48, Florida Statutes, as amended by chapter 2022-190, Laws of Florida, or the laws governing service of process in effect before January 2, 2023, which would have applied in the absence of chapter 2022-190, Laws of Florida.

“(3) The amendments made by this act apply to all service of process made or effectuated on or after October 1, 2025, regardless of whether the cause of action accrued before, on, or after October 1, 2025.

“(4) This section does not extend or modify the time for challenging the validity of any service of process and does not revive any ability to challenge the validity of service of process which has previously been waived.”

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Amendments to 48.194

Annotations, Discussions, Cases:

Cases Citing Statute 48.194

Total Results: 99

Gary McDougald Cross-Appellant v. Vivian L. Jenson, Cross-Appellee, Clarence Ehli, Cross-Appellee

786 F.2d 1465, 1986 U.S. App. LEXIS 24527

Court of Appeals for the Eleventh Circuit | Filed: Apr 21, 1986 | Docket: 111539

Cited 172 times | Published

and Florida’s long-arm statute, Fla.Stat.Ann. § 48.194 (West 1983). The father first attempted service

Electro Engineering Products Co., Inc. v. Lewis

352 So. 2d 862, 1977 Fla. LEXIS 4051

Supreme Court of Florida | Filed: Oct 27, 1977 | Docket: 1702546

Cited 49 times | Published

that service of process was proper pursuant to Section 48.194, Florida Statutes (1975), and determine that

McRae v. JD/MD, Inc.

511 So. 2d 540, 12 Fla. L. Weekly 332, 1987 Fla. LEXIS 2051

Supreme Court of Florida | Filed: Jul 9, 1987 | Docket: 1337995

Cited 47 times | Published

process on McRae in Mississippi pursuant to section 48.194. McRae filed a motion to quash service on the

Bloom v. AH Pond Co., Inc.

519 F. Supp. 1162, 1981 U.S. Dist. LEXIS 13918

District Court, S.D. Florida | Filed: Jul 27, 1981 | Docket: 894990

Cited 40 times | Published

the defendant outside this state, as provided in § 48.194. The service shall have the same effect as if

Bedford Computer Corp. v. Graphic Press, Inc.

484 So. 2d 1225, 11 Fla. L. Weekly 87, 1986 Fla. LEXIS 1724

Supreme Court of Florida | Filed: Mar 6, 1986 | Docket: 1344532

Cited 29 times | Published

to the jurisdiction of this court. However, section 48.194, Florida Statutes (1983), authorizes only personal

Madax International Corp. v. DELCHER INTERCONTINENTAL MOVING SERV. INC.

342 So. 2d 1082, 1977 Fla. App. LEXIS 15170

District Court of Appeal of Florida | Filed: Mar 2, 1977 | Docket: 2372490

Cited 25 times | Published

the defendant outside this state, as provided in § 48.194. The service shall have the same effect as it

Tracfone Wireless, Inc. v. Hernandez

196 F. Supp. 3d 1289, 2016 U.S. Dist. LEXIS 104767, 2016 WL 4131283

District Court, S.D. Florida | Filed: Jul 20, 2016 | Docket: 64309705

Cited 22 times | Published

deciding whether service was proper under Fla. Stat. § 48.194(1), which provides, in part, that “[s]ervice of

Anthony v. Gary J. Rotella & Associates

906 So. 2d 1205, 2005 WL 1682740

District Court of Appeal of Florida | Filed: Jul 20, 2005 | Docket: 1775573

Cited 20 times | Published

non-resident are sections 48.194 and 48.031. Section 48.194(1) provides that "service of process on persons

Mouzon v. Mouzon

458 So. 2d 381

District Court of Appeal of Florida | Filed: Nov 1, 1984 | Docket: 1733117

Cited 20 times | Published

voids any service of process made pursuant to section 48.194, with the result that there was no in personam

Mouzon v. Mouzon

458 So. 2d 381

District Court of Appeal of Florida | Filed: Nov 1, 1984 | Docket: 1733117

Cited 20 times | Published

voids any service of process made pursuant to section 48.194, with the result that there was no in personam

American Motors Corp. v. Abrahantes

474 So. 2d 271, 10 Fla. L. Weekly 1594

District Court of Appeal of Florida | Filed: Jun 25, 1985 | Docket: 1749863

Cited 18 times | Published

service of process in the manner provided by section 48.194, Florida Statutes (1981). AMC and Jeep timely

Atlantic Lines, Ltd. v. M/V DOMBURGH

473 F. Supp. 700, 1980 A.M.C. 2006, 1979 U.S. Dist. LEXIS 11102

District Court, S.D. Florida | Filed: Jul 11, 1979 | Docket: 2016772

Cited 16 times | Published

defendant outside this state, as provided in F.S. 48.194. The service shall have the same effect as if

In Re Amendments to Fla. Rules Civ. Proc.

604 So. 2d 1110, 1992 WL 163953

Supreme Court of Florida | Filed: Jul 16, 1992 | Docket: 1686576

Cited 15 times | Published

action for possession of residential premises), and § 48.194 (personal service outside the state), Florida

Kimbrough v. Rowe

479 So. 2d 867, 11 Fla. L. Weekly 1

District Court of Appeal of Florida | Filed: Dec 19, 1985 | Docket: 463605

Cited 14 times | Published

voids any service of process made pursuant to section 48.194, Florida Statutes (1983). Mouzon v. Mouzon

PSR ASSOC. v. Artcraft-Health

364 So. 2d 855

District Court of Appeal of Florida | Filed: Nov 29, 1978 | Docket: 461853

Cited 13 times | Published

Section 48.161 or as singularly required by Section 48.194. The record only shows that service of process

Dimino v. Farina

572 So. 2d 552, 1990 WL 205502

District Court of Appeal of Florida | Filed: Dec 19, 1990 | Docket: 479560

Cited 12 times | Published

effect service of process in accordance with section 48.194, Florida Statutes (1989), the trial court's

FIRST NAT. BK. OF KISSIMMEE v. Dunham

342 So. 2d 1021

District Court of Appeal of Florida | Filed: Feb 11, 1977 | Docket: 421052

Cited 12 times | Published

Statutes (1973), served Dilbeck in accordance with Section 48.194, Florida Statutes (1973). Dilbeck moved to

Shepheard v. Deutsche Bank Trust Co.

922 So. 2d 340, 2006 WL 435697

District Court of Appeal of Florida | Filed: Feb 24, 2006 | Docket: 1282633

Cited 11 times | Published

service through registered mail as authorized by section 48.194, Florida Statutes (2003), to any address in

Wynn v. Aetna Life Insurance Company

400 So. 2d 144

District Court of Appeal of Florida | Filed: Jun 17, 1981 | Docket: 1677301

Cited 10 times | Published

was erroneously served in Tennessee pursuant to § 48.194, Fla. Stat. (1979).[*] The use of this statute

Tucker v. Dianne Elec., Inc.

389 So. 2d 683, 1980 Fla. App. LEXIS 17514

District Court of Appeal of Florida | Filed: Oct 29, 1980 | Docket: 1282053

Cited 10 times | Published

by a sheriff in Tucker's state, pursuant to section 48.194. Service under section 48.071 requires proof

CARIBE & PANAMA INVS. v. Christensen

375 So. 2d 601

District Court of Appeal of Florida | Filed: Oct 2, 1979 | Docket: 346555

Cited 10 times | Published

serve the defendant out of state pursuant to Section 48.194. Although Section 48.193(g) authorizes service

McCabe v. McCabe

600 So. 2d 1181, 1992 WL 106958

District Court of Appeal of Florida | Filed: May 22, 1992 | Docket: 539420

Cited 9 times | Published

the wife must be properly served pursuant to section 48.194 of the Florida Statutes (1991). The wife also

In Re Amendments to Rules of Civ. Proc.

536 So. 2d 974

Supreme Court of Florida | Filed: Dec 30, 1988 | Docket: 1759905

Cited 9 times | Published

action for possession of residential premises), and § 48.194 (personal service outside the state). The former

EGF Tampa Associates v. Bohlen

532 So. 2d 1318, 1988 WL 113141

District Court of Appeal of Florida | Filed: Oct 28, 1988 | Docket: 1510269

Cited 8 times | Published

residents of New York and were served there, section 48.194, Florida Statutes (1985), requires that service

Weatherhead Co. v. Coletti

392 So. 2d 1342

District Court of Appeal of Florida | Filed: Nov 25, 1980 | Docket: 1678190

Cited 8 times | Published

disadvantage appears in this case. [7] Pursuant to Section 48.194, Florida Statutes (1979). [8] This will no

Underwood v. University of Kentucky

390 So. 2d 433, 1980 Fla. App. LEXIS 18127

District Court of Appeal of Florida | Filed: Nov 18, 1980 | Docket: 2553165

Cited 8 times | Published

personally served out-of-state pursuant to Section 48.194. Since the defendants were not personally served

ABL Realty Corp. v. Cohl

384 So. 2d 1351

District Court of Appeal of Florida | Filed: Jul 2, 1980 | Docket: 1268672

Cited 8 times | Published

personally served within this state. In turn, Section 48.194 provides: Service of process on persons outside

Berne v. Beznos

819 So. 2d 235, 2002 WL 1285071

District Court of Appeal of Florida | Filed: Jun 12, 2002 | Docket: 1503378

Cited 7 times | Published

that it does not comply with Florida law. See § 48.194(1), Fla. Stat. (2000). The trial court denied

Barrios v. Sunshine State Bank

456 So. 2d 590, 9 Fla. L. Weekly 2110, 1984 Fla. App. LEXIS 15301

District Court of Appeal of Florida | Filed: Oct 2, 1984 | Docket: 1446904

Cited 7 times | Published

193(1)(g), Florida Statutes (1983), must satisfy section 48.194, Florida Statutes (1983),[1] and it did not

Lee B. Stern & Co., Ltd. v. Green

398 So. 2d 918

District Court of Appeal of Florida | Filed: May 5, 1981 | Docket: 2532747

Cited 7 times | Published

defendants were properly served pursuant to section 48.194, Florida Statutes (1979), and actually received

FEDERAL NAT. MORTG. ASS'N v. Fandino

751 So. 2d 752, 2000 WL 227978

District Court of Appeal of Florida | Filed: Mar 1, 2000 | Docket: 1712561

Cited 6 times | Published

quashing service of process made pursuant to section 48.194, Florida Statutes (1997), on the appellees

Henzel v. Noel

598 So. 2d 220, 1992 WL 92501

District Court of Appeal of Florida | Filed: May 8, 1992 | Docket: 1472918

Cited 6 times | Published

the State of Florida is made in the same manner. § 48.194, Fla. Stat. (1991). These statutes are to be strictly

Nuta v. M/V "Fountas Four,"

753 F. Supp. 352, 1990 U.S. Dist. LEXIS 17649, 1990 WL 238336

District Court, S.D. Florida | Filed: Mar 30, 1990 | Docket: 1023588

Cited 6 times | Published

e. personal service on the non-resident under § 48.194 of Florida Statutes. To be sure, Judge Hastings'

Plummer v. Hoover

519 So. 2d 1158, 1988 WL 10840

District Court of Appeal of Florida | Filed: Feb 18, 1988 | Docket: 1698538

Cited 6 times | Published

voids any service of process made pursuant to section 48.194, Florida Statutes (1983). Mouzon v. Mouzon

Damoth v. Reinitz

485 So. 2d 881, 11 Fla. L. Weekly 746

District Court of Appeal of Florida | Filed: Mar 26, 1986 | Docket: 1680901

Cited 6 times | Published

Indiana by an authorized officer pursuant to section 48.194, Florida Statutes (1983).

Thompson v. King

523 F. Supp. 180, 1981 U.S. Dist. LEXIS 14823

District Court, M.D. Florida | Filed: Sep 10, 1981 | Docket: 2143767

Cited 6 times | Published

the person of their contents. Florida Statutes § 48.194 (1979) provides that service on persons outside

Vega Glen v. Club Méditerranée S.A.

359 F. Supp. 2d 1352, 18 A.L.R. Fed. 2d 827, 2005 U.S. Dist. LEXIS 3274, 2005 WL 497816

District Court, S.D. Florida | Filed: Feb 16, 2005 | Docket: 2337586

Cited 5 times | Published

outside this state, as provided in § 48.194." However, pursuant to § 48.194, "[s]ervice of process on persons

PAFCO GENERAL INS. v. Wah-Wai Furniture

701 So. 2d 902, 1997 WL 731400

District Court of Appeal of Florida | Filed: Nov 26, 1997 | Docket: 1736912

Cited 5 times | Published

personally served in Hong Kong pursuant to section 48.194(1), Florida Statutes (1995),[1] they moved

Cohen v. Drucker

677 So. 2d 953, 1996 WL 426080

District Court of Appeal of Florida | Filed: Jul 31, 1996 | Docket: 1270433

Cited 5 times | Published

failed to indicate the manner of service, see § 48.194(1), Fla. Stat. (1995), Drucker does not allege

Laney v. Laney

487 So. 2d 1109, 11 Fla. L. Weekly 794

District Court of Appeal of Florida | Filed: Apr 4, 1986 | Docket: 1797461

Cited 5 times | Published

voids any service of process made pursuant to section 48.194, with the result that there ... [is] no in

American Motors Corporation v. Abrahantes

446 So. 2d 240

District Court of Appeal of Florida | Filed: Mar 6, 1984 | Docket: 1779894

Cited 5 times | Published

served with process in the manner provided in Section 48.194, Florida Statutes (1981), that is, by personally

Bradford White Corp. v. Aetna Ins. Co.

372 So. 2d 994, 1979 Fla. App. LEXIS 15398

District Court of Appeal of Florida | Filed: Jul 10, 1979 | Docket: 320126

Cited 5 times | Published

personally served out of the state pursuant to Section 48.194, Florida Statutes (1977). P.S.R. Assoc. v.

Barton v. Keyes Company

305 So. 2d 269

District Court of Appeal of Florida | Filed: Dec 31, 1974 | Docket: 1308288

Cited 5 times | Published

of process was attempted pursuant to Fla. Stat. § 48.194. The Bartons moved to dismiss on the grounds that

Paola A. Alvardo-Fernandez v. Matthew Mazoff

151 So. 3d 8, 2014 Fla. App. LEXIS 15631, 2014 WL 4988409

District Court of Appeal of Florida | Filed: Oct 8, 2014 | Docket: 1432430

Cited 4 times | Published

provided in s. 48.194.” The relevant provision of section 48.194, Florida Statutes (2013), is subsection (1)

Lewis v. Fifth Third Mortgage Co.

38 So. 3d 157, 2010 Fla. App. LEXIS 1362, 2010 WL 445896

District Court of Appeal of Florida | Filed: Feb 10, 2010 | Docket: 60294555

Cited 4 times | Published

registered mail, in strict compliance with section 48.194, Florida Statutes (2007). If upon inquiry,

Carter v. Lil'Joe Records, Inc.

829 So. 2d 953, 2002 WL 31422448

District Court of Appeal of Florida | Filed: Oct 30, 2002 | Docket: 1454340

Cited 4 times | Published

the same manner as service within this state, section 48.194(1), Florida Statutes (2000), the process server

INTERCARGA INTERNACIONAL v. Harper

659 So. 2d 1208, 1995 WL 497232

District Court of Appeal of Florida | Filed: Aug 23, 1995 | Docket: 1748178

Cited 4 times | Published

failure to comply with the process provisions of section 48.194, Florida Statutes (1993). The complaint was

Lester v. ARB

658 So. 2d 583, 1995 WL 390360

District Court of Appeal of Florida | Filed: Jul 5, 1995 | Docket: 1525132

Cited 4 times | Published

voids any service of process made pursuant to F.S. 48.194. Plummer v. Hoover, 519 So.2d 1158 (Fla. 5th

Neff v. Adler

416 So. 2d 1240

District Court of Appeal of Florida | Filed: Jul 21, 1982 | Docket: 1654848

Cited 4 times | Published

had been personally served within this state. Section 48.194 provides: Personal service outside state.

Gaskill v. May Bros., Inc.

372 So. 2d 98, 1979 Fla. App. LEXIS 14618

District Court of Appeal of Florida | Filed: May 9, 1979 | Docket: 1325403

Cited 4 times | Published

served within the State of Illinois pursuant to Section 48.194, Florida Statutes (1977). The Illinois deputy's

Palmer v. Palmer

353 So. 2d 1271

District Court of Appeal of Florida | Filed: Jan 20, 1978 | Docket: 424261

Cited 4 times | Published

with process outside this state as provided in Section 48.194. This service shall have the same effect as

Godsell v. United Guar. Residential Ins.

923 So. 2d 1209, 2006 WL 664227

District Court of Appeal of Florida | Filed: Mar 17, 2006 | Docket: 1496428

Cited 3 times | Published

Schneider, 686 So.2d 742 (Fla. 2d DCA 1997). Section 48.194, Florida Statutes, which is entitled "Personal

Tennessee Farmers Mut. Ins. Co. v. Meador

467 So. 2d 471, 10 Fla. L. Weekly 1001, 1985 Fla. App. LEXIS 13537

District Court of Appeal of Florida | Filed: Apr 18, 1985 | Docket: 1274349

Cited 3 times | Published

on Tennessee Farmers was accomplished under section 48.194, Florida Statutes, through a public officer

Gutterman-Musicant-Kreitzman, Inc. v. IG Realty Co.

426 So. 2d 1216

District Court of Appeal of Florida | Filed: Feb 9, 1983 | Docket: 1283471

Cited 3 times | Published

*1217 personally in New Jersey pursuant to Section 48.194, Florida Statutes (1981). Gutterman timely

Firestone Steel Products Co. of Canada v. Snell

423 So. 2d 979

District Court of Appeal of Florida | Filed: Dec 14, 1982 | Docket: 2569059

Cited 3 times | Published

personally served with process pursuant to section 48.194 as required to confer jurisdiction under section

Yachts v. Ray Richard, Inc.

347 So. 2d 779

District Court of Appeal of Florida | Filed: Jun 21, 1977 | Docket: 1290919

Cited 3 times | Published

Section 48.193(2), Florida Statutes (1975). See Section 48.194, Florida Statutes (1975). The order appealed

Bevilacqua v. U.S. Bank, N.A.

194 So. 3d 461, 2016 Fla. App. LEXIS 7916, 2016 WL 3001138

District Court of Appeal of Florida | Filed: May 25, 2016 | Docket: 3067235

Cited 2 times | Published

Extrajudicial Documents in Civil or Commercial Matters.” § 48.194(1), Fla. , Stat. (2015): The Hague Convention

Allied Specialty Insurance v. Ohio Water Parks, Inc.

699 F. Supp. 878, 1988 U.S. Dist. LEXIS 12853, 1988 WL 122512

District Court, M.D. Florida | Filed: Nov 16, 1988 | Docket: 885404

Cited 2 times | Published

governing service of process in this cause is Section 48.194, Fla.Stat., which provides for service on:

Nettles v. White

439 So. 2d 1048

District Court of Appeal of Florida | Filed: Nov 2, 1983 | Docket: 1677763

Cited 2 times | Published

commits a tortious act within this state. Under section 48.194, Florida Statutes (1981), personal service

NATL LEAGUE FOR NURSING v. Bluestone

388 So. 2d 1090

District Court of Appeal of Florida | Filed: Oct 7, 1980 | Docket: 419656

Cited 2 times | Published

personal service upon the defendant pursuant to Section 48.194, Florida Statutes (1979), Bradford White Corp

Walsh v. Walsh

388 So. 2d 240

District Court of Appeal of Florida | Filed: Aug 15, 1980 | Docket: 1520820

Cited 2 times | Published

personally under Florida's long arm statute, Section 48.194, Florida Statutes (1979).[3] The husband, having

Volkswagen Aktiengesellschaft v. Jones

227 So. 3d 150, 2017 WL 2180984, 2017 Fla. App. LEXIS 6958

District Court of Appeal of Florida | Filed: May 17, 2017 | Docket: 6062499

Cited 1 times | Published

361 (hereinafter Hague Convention). See also § 48.194(1), Fla. Stat. (2011) (providing that service

Portalp International SAS v. Zuloaga

198 So. 3d 669, 2015 Fla. App. LEXIS 18936, 2015 WL 9258496

District Court of Appeal of Florida | Filed: Dec 18, 2015 | Docket: 3022465

Cited 1 times | Published

(3d Cir.2006)). . III. Discussion Section 48.194(1), Florida Statutes (2014), provides, in part

INTERN. COMPUTER SOLUTIONS, INC. v. St. James Club Antigua

561 So. 2d 1202, 1990 Fla. App. LEXIS 2165, 1990 WL 37383

District Court of Appeal of Florida | Filed: Apr 3, 1990 | Docket: 2586589

Cited 1 times | Published

process is thereafter properly obtained under Section 48.194, Florida Statutes (1987). We reach this result

Dept. of Health & Rehab. Services v. Wright

522 So. 2d 838, 1988 WL 34015

Supreme Court of Florida | Filed: Apr 14, 1988 | Docket: 1191919

Cited 1 times | Published

address this issue, it would have done so in section 48.194(1)(e), which pertains directly to actions in

Tetley v. Lett

462 So. 2d 1126, 1984 Fla. App. LEXIS 13657

District Court of Appeal of Florida | Filed: Jun 13, 1984 | Docket: 64609597

Cited 1 times | Published

not exceeding $10, in the court’s discretion. Section 48.194, Florida Statutes (1981), provides: 48.194

Risman v. Whittaker

326 So. 2d 213

District Court of Appeal of Florida | Filed: Feb 6, 1976 | Docket: 1729152

Cited 1 times | Published

the defendant outside this state, as provided in § 48.194. The service shall have the same effect as if

CRAIG A. MARLOWE vs CITY OF ST. AUGUSTINE, KEVIN VAN DYKE, MARCY A. VAN DYKE, PAUL A. LEONARD AND SUSAN J. LEONARD, TRUSTEES OF THE LEONARD FAMILY REVOCABLE LIVING TRUST DATED 23RD JANUARY, 2007, ET AL

District Court of Appeal of Florida | Filed: Sep 8, 2023 | Docket: 68034255

Published

process under [section] 48.194[5] cannot be had, service of process 5 Section 48.194, Florida Statutes

CRAIG A. MARLOWE vs CITY OF ST. AUGUSTINE, KEVIN VAN DYKE, MARCY A. VAN DYKE, PAUL A. LEONARD AND SUSAN J. LEONARD, TRUSTEES OF THE LEONARD FAMILY REVOCABLE LIVING TRUST DATED 23RD JANUARY, 2007, ET AL

District Court of Appeal of Florida | Filed: Jul 14, 2023 | Docket: 68034255

Published

process under [section] 48.194[5] cannot be had, service of process by Section 48.194, Florida Statutes

HELGA ZIELCKE v. ILVA RUBIO

District Court of Appeal of Florida | Filed: Jun 29, 2022 | Docket: 63556646

Published

legally cognizable exception to such compliance. § 48.194(1), Fla. Stat. (2020) (“Service of process on

KEVIN CHRISTOPHER CORRIDON v. GRACE-ELIZABETH CAROLYN CORRIDON

District Court of Appeal of Florida | Filed: Feb 17, 2021 | Docket: 59295939

Published

was effected. We note the recent change to section 48.194, Florida Statutes, which was in effect before

Ingenieria Y Exportacion De Tecnologia S.L. v. Freytech, Inc.

210 So. 3d 211, 2016 Fla. App. LEXIS 19257

District Court of Appeal of Florida | Filed: Dec 28, 2016 | Docket: 4559183

Published

694 So.2d 805, 812 (Fla. 4th DCA 1997)); see § 48.194(1), Fla. Stat. (2016). Here, the trial found that

James Matthews and Roberta Matthews v. U.S. Bank, National Association, etc.

197 So. 3d 1140, 2016 Fla. App. LEXIS 10027, 2016 WL 3541007

District Court of Appeal of Florida | Filed: Jun 29, 2016 | Docket: 3088366

Published

complied, with section 48.194, Florida Statutes, for out-of-state service. ■ Section 48.194, Florida

SDS-IC v. Florida Concentrates International, LLC

157 So. 3d 389, 2015 Fla. App. LEXIS 1232, 2015 WL 403999

District Court of Appeal of Florida | Filed: Jan 30, 2015 | Docket: 2629738

Published

country.”). With regard to Florida law, section 48.194(1), Florida Statutes (2012), provides that

Puigbo v. Medex Trading, LLC

209 So. 3d 598, 2014 Fla. App. LEXIS 15279

District Court of Appeal of Florida | Filed: Oct 1, 2014 | Docket: 1400834

Published

provided in s. 48.194.” The relevant provision of section 48.194, Florida Statutes (2013), is subsection (1)

Puigbo v. Medex Trading, LLC

District Court of Appeal of Florida | Filed: Jul 30, 2014 | Docket: 371757

Published

provided in s. 48.194.” The relevant provision of section 48.194, Florida Statutes (2013), is subsection (1)

Chigurupati v. Progressive American Insurance

132 So. 3d 263, 2013 WL 6478818, 2013 Fla. App. LEXIS 19642

District Court of Appeal of Florida | Filed: Dec 11, 2013 | Docket: 60238394

Published

LLC, 31 So.3d 304, 306 (Fla. 4th DCA 2010). Section 48.194 governs personal service outside the State

Koechli v. BIP International, Inc.

861 So. 2d 501, 2003 Fla. App. LEXIS 18678, 2003 WL 22880657

District Court of Appeal of Florida | Filed: Dec 8, 2003 | Docket: 64827018

Published

while his sailboat was docked in the Bahamas. Section 48.194(1), Florida Statutes (2002), authorizes that

Brown v. Brown

786 So. 2d 611, 2001 Fla. App. LEXIS 4794, 2001 WL 360147

District Court of Appeal of Florida | Filed: Apr 12, 2001 | Docket: 64805785

Published

shown to exist, service obtained pursuant to section 48.194 does not provide in personam jurisdiction over

General de Seguros, S.A. v. Consolidated Property & Casualty Insurance Co.

776 So. 2d 990, 2001 Fla. App. LEXIS 281, 2001 WL 37800

District Court of Appeal of Florida | Filed: Jan 17, 2001 | Docket: 64803349

Published

Haese, 649 So.2d 905, 907 (Fla. 4th DCA 1995). Section 48.194(2)(a) requires, among other things, that the

Federal National Mortgage Ass'n v. Fandino

751 So. 2d 752, 2000 Fla. App. LEXIS 2012

District Court of Appeal of Florida | Filed: Mar 1, 2000 | Docket: 64795226

Published

quashing service of process made pursuant to section 48.194, Florida Statutes (1997), on the appellees

Betancourt v. Villar-Pinero

748 So. 2d 1058, 1999 Fla. App. LEXIS 16574, 1999 WL 1111791

District Court of Appeal of Florida | Filed: Dec 8, 1999 | Docket: 64794024

Published

such service in this case is that set out in section 48.194, Florida Statutes (1999), which method was

Helbig v. Schneider

686 So. 2d 742, 1997 Fla. App. LEXIS 93, 1997 WL 7133

District Court of Appeal of Florida | Filed: Jan 10, 1997 | Docket: 64770438

Published

engaging in business in this state, and to section 48.194 which provides for personal service on persons

Takiff ex rel. Stateman v. Takiff

683 So. 2d 595, 1996 Fla. App. LEXIS 11905, 1996 WL 661751

District Court of Appeal of Florida | Filed: Nov 13, 1996 | Docket: 64769344

Published

Petition for Dissolution of Marriage. Pursuant to section 48.194, Florida Statutes (1995), service on a nonresident

Taito Corp. v. Ferris

681 So. 2d 1156, 1996 Fla. App. LEXIS 8913, 1996 WL 475723

District Court of Appeal of Florida | Filed: Aug 23, 1996 | Docket: 64768532

Published

of Taito America, in Illinois, pursuant to Section 48.194. On April 26,1995 a default was entered against

Gross v. Fidelity Federal Savings Bank of Florida

579 So. 2d 846, 1991 Fla. App. LEXIS 4430, 1991 WL 76529

District Court of Appeal of Florida | Filed: May 15, 1991 | Docket: 64658806

Published

the mortgagee must use personal service under section 48.194. Fidelity sued Robert and Carol Gross to foreclose

Pina v. Simon-Pina

544 So. 2d 1161, 14 Fla. L. Weekly 1452, 1989 Fla. App. LEXIS 3396, 1989 WL 63376

District Court of Appeal of Florida | Filed: Jun 15, 1989 | Docket: 64643163

Published

insufficient. The affidavit filed pursuant to section 48.194 fails to state the time of service, and the

Wadkin Ltd. v. Platt

545 So. 2d 314, 14 Fla. L. Weekly 1027, 1989 Fla. App. LEXIS 2260, 1989 WL 39570

District Court of Appeal of Florida | Filed: Apr 26, 1989 | Docket: 64643251

Published

pursuant to the Florida Long Arm Statute, section 48.194 (1987). After several unsuccessful attempts

Alexander & Alexander of the Carolinas, Inc. v. Northwest Oxygen, Inc.

541 So. 2d 1238, 14 Fla. L. Weekly 501, 1989 Fla. App. LEXIS 767, 1989 WL 11962

District Court of Appeal of Florida | Filed: Feb 17, 1989 | Docket: 64641969

Published

not perfect service of process pursuant to section 48.194, Florida Statutes, as is contemplated by section

Blackmon v. Blackmon

487 So. 2d 1131, 1986 Fla. App. LEXIS 7441, 11 Fla. L. Weekly 952

District Court of Appeal of Florida | Filed: Apr 22, 1986 | Docket: 64619056

Published

*1132service on the non-resident defendant pursuant to section 48.194. Nettles v. White, 439 So.2d 1048 (Fla. 2d

McRae v. J.D./M.D., Inc.

481 So. 2d 945, 11 Fla. L. Weekly 117, 1985 Fla. App. LEXIS 6077

District Court of Appeal of Florida | Filed: Dec 31, 1985 | Docket: 64616781

Published

contract and obtained service of process under section 48.-194 on said defendants in Mississippi. McRae moved

American Motors Corp. v. Abrahantes

474 So. 2d 271, 10 Fla. L. Weekly 1594, 1985 Fla. App. LEXIS 15376

District Court of Appeal of Florida | Filed: Jun 25, 1985 | Docket: 64613673

Published

service of process in the manner provided by section 48.194, Florida Statutes (1981). AMC and Jeep timely

MacIvor v. Volvo Penta of America, Inc.

471 So. 2d 187, 1985 Fla. App. LEXIS 14641, 10 Fla. L. Weekly 1528

District Court of Appeal of Florida | Filed: Jun 18, 1985 | Docket: 64612677

Published

the person is served,” failed to comply with Section 48.194, Florida Statutes (1983), is reversed upon

Trammell v. Coral Ridge Interiors, Inc.

457 So. 2d 593, 9 Fla. L. Weekly 2221, 1984 Fla. App. LEXIS 15570

District Court of Appeal of Florida | Filed: Oct 17, 1984 | Docket: 64607423

Published

that personal service on a nonresident per section 48.194 should be more effective than service through

McIntyre v. Lamb

421 So. 2d 822, 1982 Fla. App. LEXIS 21616

District Court of Appeal of Florida | Filed: Nov 17, 1982 | Docket: 64593189

Published

then be served in a manner satisfactory to section 48.194, even if timing problems prevented compliance

Colorado Central Credit Union v. Winters Government Securities Corp.

376 So. 2d 25, 1979 Fla. App. LEXIS 15564

District Court of Appeal of Florida | Filed: Oct 3, 1979 | Docket: 64572424

Published

obtained under the Florida Long Arm Statute, Section 48.194, Florida Statutes (1977). Motions to dismiss

Biscayne Athletic Club, Inc. v. Iacono

367 So. 2d 275, 1979 Fla. App. LEXIS 14445

District Court of Appeal of Florida | Filed: Feb 13, 1979 | Docket: 64568442

Published

New York, was served in New York pursuant to Section 48.194 Florida Statutes which creates long-arm jurisdiction

Yoder v. Yoder

363 So. 2d 409, 1978 Fla. App. LEXIS 16802

District Court of Appeal of Florida | Filed: Oct 19, 1978 | Docket: 64566651

Published

was personally served in Nevada pursuant to Section 48.194, Florida Statutes (1977), but he has never

Connell v. Ott Research & Development, Inc.

363 So. 2d 163, 1978 Fla. App. LEXIS 16762

District Court of Appeal of Florida | Filed: Oct 10, 1978 | Docket: 64566565

Published

utilization of the personal service provision of Section 48.194 was ineffective as a means of gaining jurisdiction