Florida Statutes
Fla. Stat. § 86.061 (2025)
Supplemental relief.
✓ 2025 Florida Statutes — current through the 2025 Regular Session
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86.061 Supplemental relief.—Further relief based on a declaratory judgment may be granted when necessary or proper. The application therefor shall be by motion to the court having jurisdiction to grant relief. If the application is sufficient, the court shall require any adverse party whose rights have been adjudicated by the declaratory judgment to show cause on reasonable notice, why further relief should not be granted forthwith.
Note.—Former s. 87.07.
Notes of Decisions
Cited in 45
cases (9 in the last 5 years), 1970–2026 · leading case: Florida House of Representatives v. League of Women Voters of Florida, 118 So. 3d 198 (Fla. 2013).
Florida House of Representatives v. League of Women Voters of Florida, 118 So. 3d 198 (Fla. 2013). “In its 1972 “Order Clarifying Opinion and Denying Rehearing,” in what could only be described as a supplemental advisory opinion, the Court expressed the view that a post-validation challenge could be brought “by supplemental relief’ as authorized by the declaratory judgment law…”
Mills v. Ball, 344 So. 2d 635 (Fla. 1st DCA 1977). “Predicated upon the petition, the trial court entered an ex parte order stating that the allegations of the petition were sufficient under § 86.061, Fla. Stat. (1975), to establish a prima facie case of jurisdiction and directing petitioners to serve (as they did) a copy of the…”
Leroy Mack v. USAA Cas. Ins. Co., 994 F.3d 1353 (11th Cir. 2021). “§ 2202 ; Fla. Stat. § 86.061 . And, although we have not addressed the issue, other courts have interpreted both statutes as allowing money damages as a form of supplemental relief.”
In Re Apportionment Law, Senate Jt. Res. No. 1305, 263 So. 2d 797 (Fla. 1972). “However, since this situation cannot be avoided due to the majority's holding today, aggrieved citizens would do well to remember that this is essentially a declaratory judgment proceeding; therefore, the provisions of Fla. Stat. § 86.061 , relating to supplemental relief,…”
Inphynet Contracting Servs., Inc., d/b/a Emergency Physicians of Delray, a Florida Corp., MD Now Med. Centers, etc. v. R v. Matthews III, Patricia Maher, Ron Depaolo, & Lauren McKelvey, as Pers. Rep. of the Est. of Scott M. McKelvey, etc., 196 So. 3d 449 (Fla. 4th DCA 2016). “In this case, the plaintiff class is seeking damages and “any other relief the Court deems proper and just” for violation of FDUTPA, as well as, “supplemental relfef that may be appropriate under Section 86.061, Fla. Stat.” FDUTPA allows for injunctive relief, and injunctive…”
Hi-Shear Tech. Corp. v. United Space All., LLC, 1 So. 3d 195 (Fla. 2d DCA 2008). “Although it could have been awarded these damages as part of its request for declaratory judgment, Hi-Shear neither pled for these damages nor sought supplemental relief pursuant to section 86.061, Florida Statutes (2000). In fact, the first time Hi-Shear raised this issue was…”
Days Inns Acquisition Corp. v. Hutchinson, 707 So. 2d 747 (Fla. 4th DCA 1997). “See § 86.061, Fla. Stat. (1995). [6] By this opinion we do not imply that Days Inns can participate as a party or otherwise defend against plaintiff's claim against Transcall.”
Bd. of Regents v. Stinson-Head, Inc., 504 So. 2d 1374 (Fla. 4th DCA 1987). “[Emphasis added.] H. Trawick, Trawick's Florida Practice and Procedure § 25-4 (1986 ed.”
Mcallister v. Breakers Seville Ass'n, Inc., 41 So. 3d 405 (Fla. 4th DCA 2010). “If the application is sufficient, the court shall require any adverse party whose rights have been adjudicated by the declaratory judgment to show cause on reasonable notice, why further relief should not be granted forthwith.”
Trafalgar Developers, Ltd. v. Morley, 305 So. 2d 274 (Fla. 3d DCA 1974). “Upon remand, the circuit court entered its order dismissing plaintiff's complaint with prejudice and retaining jurisdiction in the cause for the purpose of considering any motion for supplemental relief filed by defendants pursuant to § 86.061, Fla. Stat. Plaintiff-appellant…”
Port Everglades Auth. v. ILA, 652 So. 2d 1169 (Fla. 4th DCA 1995). “ILA asserts that section 86.061, Florida Statutes (1991), the supplemental relief section of the Declaratory Judgment Act, authorizes the trial court's assertion of continuing jurisdiction.”
State Farm Mut. Auto. Ins. Co. v. Kendrick, 780 So. 2d 231 (Fla. 3d DCA 2001). “Jo Carol Kendrick, plaintiff in the underlying class action suit for declaratory relief pursuant to Section 86.061 Florida Statutes (1999), is seeking to represent all State Farm insureds in Florida involved in auto collisions allegedly entitled to "uncompensated property losses.”
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