Florida Statute 63.182 - Full Text and Legal Analysis

The 2025 Florida Statutes

Title VI
CIVIL PRACTICE AND PROCEDURE

Chapter 63
ADOPTION

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F.S. 63.182

63.182 Statute of repose.—

(1) Notwithstanding s. 95.031 or s. 95.11 or any other statute, an action or proceeding of any kind to vacate, set aside, or otherwise nullify a judgment of adoption or an underlying judgment terminating parental rights on any ground may not be filed more than 1 year after entry of the judgment terminating parental rights.

(2)(a) Except for the specific persons expressly entitled to be given notice of an adoption in accordance with this chapter, the interest that entitles a person to notice of an adoption must be direct, financial, and immediate, and the person must show that he or she will gain or lose by the direct legal operation and effect of the judgment. A showing of an indirect, inconsequential, or contingent interest is wholly inadequate, and a person with this indirect interest lacks standing to set aside a judgment of adoption.

(b) This subsection is remedial and shall apply to all adoptions, including those in which a judgment of adoption has already been entered.

History.—s. 18, ch. 73-159; s. 6, ch. 2000-188; s. 32, ch. 2003-58; s. 32, ch. 2003-154; s. 4, ch. 2006-265.

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Amendments to 63.182

Annotations, Discussions, Cases:

Cases Citing Statute 63.182

Total Results: 24

In Re Adoption of a Minor Child

593 So. 2d 185, 16 Fla. L. Weekly Supp. 771, 1991 Fla. LEXIS 2126, 1991 WL 259752

Supreme Court of Florida | Filed: Dec 12, 1991 | Docket: 1508912

Cited 18 times | Published

are within the one-year period permitted by section 63.182, Florida Statutes (1987), to attack a final

Peregood v. Cosmides

663 So. 2d 665, 1995 WL 627459

District Court of Appeal of Florida | Filed: Oct 27, 1995 | Docket: 1313758

Cited 13 times | Published

children's minority. [3] We are aware that section 63.182, Florida Statutes (1993) provides that: [a]fter

Amendments to the Florida Family Law Rules

713 So. 2d 1, 23 Fla. L. Weekly Supp. 105, 1998 Fla. LEXIS 475, 1998 WL 166533

Supreme Court of Florida | Filed: Feb 26, 1998 | Docket: 1732751

Cited 7 times | Published

child(ren). 3. I understand pursuant to section 63.182, Florida Statutes, that: "After one year

Dennis v. Kline

120 So. 3d 11, 2013 Fla. App. LEXIS 9614, 2013 WL 3014115

District Court of Appeal of Florida | Filed: Jun 19, 2013 | Docket: 60233880

Cited 5 times | Published

interested parties. See 23 Pa.C.S.A. § 2713.10 Section 63.182(2)(a), Florida Statutes (2011), sets the notice

Calderon v. Torres

445 So. 2d 1040

District Court of Appeal of Florida | Filed: Jan 17, 1984 | Docket: 2542078

Cited 5 times | Published

on the basis that the petition was barred by Section 63.182, Florida Statutes (1981). The trial court,

Amendments to the Florida Family Law Rules of Procedure & Family Law Forms

810 So. 2d 1, 26 Fla. L. Weekly Supp. 13, 2000 Fla. LEXIS 2272, 2000 WL 1352932

Supreme Court of Florida | Filed: Sep 21, 2000 | Docket: 64813197

Cited 4 times | Published

(these) children). 3. I understand pursuant to section 63.182, Florida Statutes, that: “After one year of

Mlb v. Dept. of Hlt. & Rehab. Serv.

559 So. 2d 87

District Court of Appeal of Florida | Filed: Feb 13, 1990 | Docket: 1751651

Cited 4 times | Published

seek to overturn the trial court's ruling that section 63.182, Florida Statutes (1987), and Calderon v. Torres

Mc v. Ah

745 So. 2d 396, 1999 Fla. App. LEXIS 13470, 1999 WL 817916

District Court of Appeal of Florida | Filed: Oct 13, 1999 | Docket: 1689151

Cited 2 times | Published

became final. Neither party raises or discusses section 63.182, Florida Statutes, which states that: "After

In Re Adoption of a Minor Child

570 So. 2d 340, 1990 WL 149748

District Court of Appeal of Florida | Filed: Dec 12, 1990 | Docket: 1704157

Cited 2 times | Published

1989, one year later. Appellants point to section 63.182, Florida Statutes (1987) as authority for the

F.R. v. Adoption of Baby Boy Born November 2, 2010

135 So. 3d 301, 2012 WL 1813520, 2012 Fla. App. LEXIS 8019

District Court of Appeal of Florida | Filed: May 21, 2012 | Docket: 60239541

Cited 1 times | Published

540(b)(3) provides for a one-year filing window. Section, 63.182, Florida Statutes (2010), entitled "Statute

Martin v. Adoption of L.M.D.

64 So. 3d 758, 2011 Fla. App. LEXIS 10435, 2011 WL 2652372

District Court of Appeal of Florida | Filed: Jul 5, 2011 | Docket: 60301579

Cited 1 times | Published

an independent statute of repose for adoptions. § 63.182, Fla. Stat. (2009). The statute provides that

GUARDIAN AD LITEM, K.F. AND J.F., ADOPTIVE PARENTS OF RA.W. vs DEPARTMENT OF CHILDREN AND FAMILIES, R.W., JR., AND T.W., BIOLOGICAL/FORMER PARENTS, R.W., SR., AND C.W., MATERNAL GRANDPARENTS/ADOPTIVE PARENTS OF R.W., III

District Court of Appeal of Florida | Filed: Oct 18, 2023 | Docket: 66863863

Published

barred by the statute of repose codified at section 63.182(1), Florida Statutes (2017), and thus not meet

Leggett v. Adoption GVLP

271 So. 3d 1168

District Court of Appeal of Florida | Filed: Apr 24, 2019 | Docket: 64714191

Published

PER CURIAM. Affirmed. See § 63.182(1), Fla. Stat. (2018) ("[A]n action or proceeding of any kind to

Leggett v. Adoption GVLP

271 So. 3d 1168

District Court of Appeal of Florida | Filed: Apr 24, 2019 | Docket: 64714192

Published

PER CURIAM. Affirmed. See § 63.182(1), Fla. Stat. (2018) ("[A]n action or proceeding of any kind to

J.G., THE FATHER v. DEPARTMENT OF CHILDREN AND FAMILIES

247 So. 3d 561

District Court of Appeal of Florida | Filed: May 30, 2018 | Docket: 6958945

Published

of the judgment terminating parental rights.” § 63.182(1), Fla. Stat. (2015). Since J.G. did not file

Edwards v. Maxwell

215 So. 3d 616, 2017 WL 1201873, 2017 Fla. App. LEXIS 4409

District Court of Appeal of Florida | Filed: Mar 31, 2017 | Docket: 60264843

Published

could bring an action to vacate an adoption. See § 63.182(2)(a), Fla. Stat.; Stefanos v. Rivera-Berrios

M.N., Jr. the Father v. Department of Children And Families and Guardian Ad Litem Program

161 So. 3d 1290, 2015 Fla. App. LEXIS 5107, 2015 WL 1545230

District Court of Appeal of Florida | Filed: Apr 8, 2015 | Docket: 2679412

Published

merits of the Father’s argument, we affirm. Section 63.182(1), Florida Statutes (2013), a statute of repose

Makaros v. Cichocki

159 So. 3d 957, 2015 Fla. App. LEXIS 3584, 2015 WL 1071067

District Court of Appeal of Florida | Filed: Mar 13, 2015 | Docket: 60246715

Published

notice of the stepparent adoption proceedings. See § 63.182(2)(a), Fla. Stat. (2012) (“[T]he interest that

Kemp & Associates, Inc. v. Chisholm

162 So. 3d 172, 2015 Fla. App. LEXIS 1555, 2015 WL 477856

District Court of Appeal of Florida | Filed: Feb 6, 2015 | Docket: 60247438

Published

providing six months). Florida law permits one year. § 63.182(1), Fla. Stat. (1997). . In 1975, the Florida

Goodman v. Goodman

126 So. 3d 310, 2013 WL 1222944, 2013 Fla. App. LEXIS 4927

District Court of Appeal of Florida | Filed: Mar 27, 2013 | Docket: 60236402

Published

proceeding, pursuant to section 63.182, Florida Statutes (2011). Section 63.182(2)(a) states, in pertinent

M.C. v. A.H.

745 So. 2d 396

District Court of Appeal of Florida | Filed: Oct 13, 1999 | Docket: 64792388

Published

became final. Neither party raises or discusses section 63.182, Florida Statutes, which states that: "After

Preston v. Tolone

661 So. 2d 967, 1995 Fla. App. LEXIS 11243, 1995 WL 627457

District Court of Appeal of Florida | Filed: Oct 27, 1995 | Docket: 64759547

Published

judgment, relying on section 63.182, Florida Statutes (1991). We reverse. Section 63.182 provides: After 1

Department of Health & Rehabilitative Services v. M.G.

584 So. 2d 600, 1991 Fla. App. LEXIS 7374, 16 Fla. L. Weekly Fed. D 2034

District Court of Appeal of Florida | Filed: Jul 31, 1991 | Docket: 64660961

Published

any challenge to the judgment of adoption. See § 63.182, Fla.Stat. (1985). The natural mother apparently

M.L.B. v. Department of Health & Rehabilitative Services

559 So. 2d 87, 1990 WL 11792

District Court of Appeal of Florida | Filed: Feb 13, 1990 | Docket: 64649330

Published

seek to overturn the trial court’s ruling that section 63.182, Florida Statutes (1987), and Calderon v. Torres