Florida Statutes
Fla. Stat. § 55.604 (2025)
Recognition and enforcement.
✓ 2025 Florida Statutes — current through the 2025 Regular Session
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55.604 Recognition and enforcement.—Except as provided in s. 55.605, an out-of-country foreign judgment meeting the requirements of s. 55.603 is conclusive between the parties to the extent that it grants or denies recovery of a sum of money. Procedures for recognition and enforceability of an out-of-country foreign judgment shall be as follows:
(1) The out-of-country foreign judgment shall be filed with the clerk of the court and recorded in the public records in the county or counties where enforcement is sought.
(a) At the time of the recording of an out-of-country foreign judgment, the judgment creditor shall make and record with the clerk of the circuit court an affidavit setting forth the name, social security number, if known, and last known post-office address of the judgment debtor and of the judgment creditor.
(b) Promptly upon the recording of the out-of-country foreign judgment and the affidavit, the clerk shall mail notice of the recording of the out-of-country foreign judgment, by registered mail with return receipt requested, to the judgment debtor at the address given in the affidavit and shall make a note of the mailing in the docket. The notice shall include the name and address of the judgment creditor and of the judgment creditor’s attorney, if any, in this state. In addition, the judgment creditor may mail a notice of the recording of the judgment to the judgment debtor and may record proof of mailing with the clerk. The failure of the clerk to mail notice of recording will not affect the enforcement proceedings if proof of mailing by the judgment creditor has been recorded.
(2) The judgment debtor shall have 30 days after service of the notice to file a notice of objection with the clerk of the court specifying the grounds for nonrecognition or nonenforceability under this act.
(3) Upon the application of any party, and after proper notice, the circuit court shall have jurisdiction to conduct a hearing, determine the issues, and enter an appropriate order granting or denying recognition in accordance with the terms of this act.
(4) If the judgment debtor fails to file a notice of objection within the required time, the clerk of the court shall record a certificate stating that no objection has been filed.
(5) Upon entry of an order recognizing the out-of-country foreign judgment, or upon recording of the clerk’s certificate set forth above, the out-of-country foreign judgment shall be enforced in the same manner as the judgment of a court of this state.
(6) Once an order recognizing the out-of-country foreign judgment has been entered by a court of this state, the order and a copy of the judgment may be recorded in any other county of this state without further notice or proceedings, and shall be enforceable in the same manner as the judgment of a court of this state.
(7) A lien on real estate in any county shall be created only when there has been recorded in the official records of the county (a) a certified copy of the judgment, and (b) a copy of the clerk’s certificate or the order recognizing the out-of-country foreign judgment. The priority of such lien will be established as of the time the latter of the two recordings has occurred.
(8) A judgment lien on personal property is acquired only when a judgment lien certificate is filed in accordance with s. 55.203 with the Department of State.
History.—s. 4, ch. 94-239; s. 77, ch. 99-251; s. 17, ch. 2000-258; s. 10, ch. 2001-154; s. 7, ch. 2005-241.
Notes of Decisions
Cited in 23
cases (5 in the last 5 years), 1997–2024 · leading case: Nadd v. Le Credit Lyonnais, SA, 804 So. 2d 1226 (Fla. 2001).
Nadd v. Le Credit Lyonnais, SA, 804 So. 2d 1226 (Fla. 2001). “See § 55.604, Fla. Stat. The judgment is then recorded in that county.”
Strod v. Lewenstark, 958 So. 2d 1138 (Fla. 4th DCA 2007). “Strod argues, inter alia, that the trial court's entry of final judgment violated his due process rights because Lewenstark failed to comply with section 55.604, Florida Statutes (2006), in notifying him of her domestication action.”
Kramer v. Von Mitschke-Collande, 5 So. 3d 689 (Fla. 3d DCA 2008). “Meanwhile, further proceedings were pending on another portion of the Swiss litigation, whereby an accounting was to be conducted, and eventually a second judgment for an additional amount was entered.”
Garnac Grain Co., Inc. v. Mejia, 962 So. 2d 408 (Fla. 4th DCA 2007). “§ 55.604, Fla. Stat. (2006). The Olivareses did not follow these procedures to seek court recognition of the Venezuelan judgment because they mistakenly characterized the proceedings as "pending" for the purposes of affording comity, rather than "final" for the purposes of…”
Frymer v. Brettschneider, 696 So. 2d 1266 (Fla. 4th DCA 1997). “Section 55.604 does, however, set forth a procedure for enforcement of an out-of-country judgment similar to that for enforcement of a sister state's judgment, see section 55.”
Volksbank Regensburg eG v. Burger, 703 So. 2d 538 (Fla. 4th DCA 1997). “604(1), Florida Statutes (1995), in order to have the foreign judgment recognized and enforced pursuant to section 55.604. The statute requires the clerk to mail notice of the recording, by registered mail with return receipt requested, to the judgment debtor, section 55.”
Osorio v. Dole Food Co., 665 F. Supp. 2d 1307 (S.D. Fla. 2009). “Once the party seeking to enforce the judgment follows the filing and notice requirements of Fla. Stat § 55.604, the judgment will be enforced unless the judgment debtor objects within 30 days.”
Nicor Int'l Corp. v. El Paso Corp., 292 F. Supp. 2d 1357 (S.D. Fla. 2003). “” § 55.604, Fla. Stat. (emphasis added). Pursuant to section 55.”
Le Credit Lyonnais, SA v. Nadd, 741 So. 2d 1165 (Fla. 5th DCA 1999). “More than fifteen years later, in October 1995, LCL sought to file and record the two judgments with the clerk of a Florida circuit court, pursuant to section 55.604, Florida's UFMJRA. The UFMJRA was adopted in Florida in 1994.”
Chabert v. Bacquie, 694 So. 2d 805 (Fla. 4th DCA 1997). “See § 55.604(5), (6), and (7), Fla.Stat. (1995).”
Harold v. Sanders, 159 So. 3d 338 (Fla. 2d DCA 2015). “090(e) applies to extend the time period for objecting to the recording of a foreign judgment set forth in section 55.604, Florida Statutes (1995), because section 55.”
Eos Transp. Inc. v. Agri-Source Fuels LLC, 37 So. 3d 349 (Fla. 1st DCA 2010). “See § 55.604-.605, Fla. Stat.; Osorio, 665 F.”
— 55.604(1) — 3 cases
Strod v. Lewenstark, 958 So. 2d 1138 (Fla. 4th DCA 2007). “Strod argues, inter alia, that the trial court's entry of final judgment violated his due process rights because Lewenstark failed to comply with section 55.604, Florida Statutes (2006), in notifying him of her domestication action.”
Volksbank Regensburg eG v. Burger, 703 So. 2d 538 (Fla. 4th DCA 1997). “604(1), Florida Statutes (1995), in order to have the foreign judgment recognized and enforced pursuant to section 55.604. The statute requires the clerk to mail notice of the recording, by registered mail with return receipt requested, to the judgment debtor, section 55.”
Oksana Shakhova v. Sergiy Pugachov (Fla. 4th DCA 2022).
— 55.604(1)(a) — 2 cases
Strod v. Lewenstark, 958 So. 2d 1138 (Fla. 4th DCA 2007). “Strod argues, inter alia, that the trial court's entry of final judgment violated his due process rights because Lewenstark failed to comply with section 55.604, Florida Statutes (2006), in notifying him of her domestication action.”
Oksana Shakhova v. Sergiy Pugachov (Fla. 4th DCA 2022).
— 55.604(1)(b) — 3 cases
Strod v. Lewenstark, 958 So. 2d 1138 (Fla. 4th DCA 2007). “Strod argues, inter alia, that the trial court's entry of final judgment violated his due process rights because Lewenstark failed to comply with section 55.604, Florida Statutes (2006), in notifying him of her domestication action.”
Frymer v. Brettschneider, 696 So. 2d 1266 (Fla. 4th DCA 1997). “Section 55.604 does, however, set forth a procedure for enforcement of an out-of-country judgment similar to that for enforcement of a sister state's judgment, see section 55.”
Volksbank Regensburg eG v. Burger, 703 So. 2d 538 (Fla. 4th DCA 1997). “604(1), Florida Statutes (1995), in order to have the foreign judgment recognized and enforced pursuant to section 55.604. The statute requires the clerk to mail notice of the recording, by registered mail with return receipt requested, to the judgment debtor, section 55.”
— 55.604(2) — 7 cases
Kramer v. Von Mitschke-Collande, 5 So. 3d 689 (Fla. 3d DCA 2008). “Meanwhile, further proceedings were pending on another portion of the Swiss litigation, whereby an accounting was to be conducted, and eventually a second judgment for an additional amount was entered.”
Nadd v. Le Credit Lyonnais, SA, 804 So. 2d 1226 (Fla. 2001). “See § 55.604, Fla. Stat. The judgment is then recorded in that county.”
Frymer v. Brettschneider, 696 So. 2d 1266 (Fla. 4th DCA 1997). “Section 55.604 does, however, set forth a procedure for enforcement of an out-of-country judgment similar to that for enforcement of a sister state's judgment, see section 55.”
Strod v. Lewenstark, 958 So. 2d 1138 (Fla. 4th DCA 2007). “Strod argues, inter alia, that the trial court's entry of final judgment violated his due process rights because Lewenstark failed to comply with section 55.604, Florida Statutes (2006), in notifying him of her domestication action.”
Volksbank Regensburg eG v. Burger, 703 So. 2d 538 (Fla. 4th DCA 1997). “604(1), Florida Statutes (1995), in order to have the foreign judgment recognized and enforced pursuant to section 55.604. The statute requires the clerk to mail notice of the recording, by registered mail with return receipt requested, to the judgment debtor, section 55.”
— 55.604(3) — 1 case
Strod v. Lewenstark, 958 So. 2d 1138 (Fla. 4th DCA 2007). “Strod argues, inter alia, that the trial court's entry of final judgment violated his due process rights because Lewenstark failed to comply with section 55.604, Florida Statutes (2006), in notifying him of her domestication action.”
— 55.604(4) — 2 cases
Strod v. Lewenstark, 958 So. 2d 1138 (Fla. 4th DCA 2007). “Strod argues, inter alia, that the trial court's entry of final judgment violated his due process rights because Lewenstark failed to comply with section 55.604, Florida Statutes (2006), in notifying him of her domestication action.”
Frymer v. Brettschneider, 696 So. 2d 1266 (Fla. 4th DCA 1997). “Section 55.604 does, however, set forth a procedure for enforcement of an out-of-country judgment similar to that for enforcement of a sister state's judgment, see section 55.”
— 55.604(5) — 6 cases
Nadd v. Le Credit Lyonnais, SA, 804 So. 2d 1226 (Fla. 2001). “See § 55.604, Fla. Stat. The judgment is then recorded in that county.”
Chabert v. Bacquie, 694 So. 2d 805 (Fla. 4th DCA 1997). “See § 55.604(5), (6), and (7), Fla.Stat. (1995).”
Volksbank Regensburg eG v. Burger, 703 So. 2d 538 (Fla. 4th DCA 1997). “604(1), Florida Statutes (1995), in order to have the foreign judgment recognized and enforced pursuant to section 55.604. The statute requires the clerk to mail notice of the recording, by registered mail with return receipt requested, to the judgment debtor, section 55.”
Tettamanti v. Opcion Sociedad Anonima, 201 So. 3d 3 (Fla. 3d DCA 2009).
Campbell v. Rapetti, 91 So. 3d 276 (Fla. 4th DCA 2012).
— 55.604(6) — 1 case
Le Credit Lyonnais, SA v. Nadd, 741 So. 2d 1165 (Fla. 5th DCA 1999). “More than fifteen years later, in October 1995, LCL sought to file and record the two judgments with the clerk of a Florida circuit court, pursuant to section 55.604, Florida's UFMJRA. The UFMJRA was adopted in Florida in 1994.”
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