Florida Statute 86.111 - Full Text and Legal Analysis

The 2025 Florida Statutes

Title VI
CIVIL PRACTICE AND PROCEDURE

Chapter 86
DECLARATORY JUDGMENTS

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F.S. 86.111

86.111 Existence of another adequate remedy; effect.—The existence of another adequate remedy does not preclude a judgment for declaratory relief. The court may order a speedy hearing of an action for a declaratory judgment and may advance it on the calendar. The court has power to give as full and complete equitable relief as it would have had if such proceeding had been instituted as an action in chancery.

History.—s. 12, ch. 21820, 1943; s. 2, ch. 29737, 1955; s. 38, ch. 67-254.

Note.—Former s. 87.12.

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Amendments to 86.111

Annotations, Discussions, Cases:

Cases Citing Statute 86.111

Total Results: 22

School Bd. of Leon County v. Mitchell

346 So. 2d 562, 1977 Fla. App. LEXIS 16041

District Court of Appeal of Florida | Filed: May 4, 1977 | Docket: 1411070

Cited 39 times | Published

ground that there is another adequate remedy. Section 86.111, Florida Statutes (1975). Consistent with the

Price v. Tyler

890 So. 2d 246, 2004 WL 2404056

Supreme Court of Florida | Filed: Oct 28, 2004 | Docket: 957248

Cited 38 times | Published

equitable action, such as a quiet title action. See § 86.111, Fla. Stat. (2001). For this reason, the Fourth

Kelner v. Woody

399 So. 2d 35

District Court of Appeal of Florida | Filed: May 19, 1981 | Docket: 1652284

Cited 13 times | Published

remedies does not preclude declaratory judgment, section 86.111, Florida Statutes (1979), it does bear on the

City of Coral Springs v. Florida Nat. Properties

340 So. 2d 1271

District Court of Appeal of Florida | Filed: Dec 24, 1976 | Docket: 1299105

Cited 11 times | Published

409, 417 (1933). Likewise, the provision of Section 86.111, Florida Statutes (1975), that "The existence

Miami Dolphins, Ltd. v. GENDEN & BACH, PA

545 So. 2d 294, 1989 WL 30791

District Court of Appeal of Florida | Filed: Apr 4, 1989 | Docket: 1345453

Cited 10 times | Published

existence of another remedy is not disqualifying. § 86.111, Fla. Stat. (1987). These parties have a continuing

STATE, COM'N ON ETHICS v. Sullivan

430 So. 2d 928

District Court of Appeal of Florida | Filed: Apr 19, 1983 | Docket: 1508842

Cited 10 times | Published

equitable or legal relations thereunder. Further, section 86.111 provides that the "existence of another adequate

McIntosh v. Harbour Club Villas Condo. Ass'n

468 So. 2d 1075, 10 Fla. L. Weekly 1206

District Court of Appeal of Florida | Filed: May 14, 1985 | Docket: 1725587

Cited 9 times | Published

precluded by the existence of another adequate remedy, § 86.111, Fla. Stat. (1983), such does bear on the proper

MacIejewski v. Holland

441 So. 2d 703

District Court of Appeal of Florida | Filed: Dec 7, 1983 | Docket: 1333331

Cited 7 times | Published

not preclude a judgment for declaratory relief. § 86.111, Fla. Stat. (1981). Accordingly, the appellant

Mills v. Ball

344 So. 2d 635

District Court of Appeal of Florida | Filed: Apr 15, 1977 | Docket: 474783

Cited 6 times | Published

granted forthwith." It should be further noted that § 86.111, Fla. Stat. (1975), provides in part that: "The

Orange County v. Expedia, Inc.

985 So. 2d 622, 2008 WL 2387991

District Court of Appeal of Florida | Filed: Jun 13, 2008 | Docket: 1673391

Cited 5 times | Published

remedy does not preclude" declaratory relief. § 86.111, Fla. Stat. It is well settled that to obtain

Conley v. Morley Realty Corp.

575 So. 2d 253, 1991 Fla. App. LEXIS 958, 1991 WL 15561

District Court of Appeal of Florida | Filed: Feb 12, 1991 | Docket: 1731175

Cited 4 times | Published

not preclude a judgment for declaratory relief." § 86.111, Fla. Stat. (1989). The order of dismissal must

Transp. Cas. Ins. v. Soil Tech Distributors

966 So. 2d 8, 2007 WL 2254551

District Court of Appeal of Florida | Filed: Aug 8, 2007 | Docket: 1270883

Cited 2 times | Published

not preclude a judgment for declaratory relief." § 86.111, Fla. Stat. Moreover, the availability of a remedy

State, Dept. of Revenue v. Ray Const.

667 So. 2d 859, 1996 Fla. App. LEXIS 537, 1996 WL 31884

District Court of Appeal of Florida | Filed: Jan 30, 1996 | Docket: 1511579

Cited 2 times | Published

guidance of which we are aware is found in section 86.111, in which the legislature specifically stated:

Angelo's Aggregate Materials, Ltd. v. Pasco County

118 So. 3d 971, 2013 WL 4081010, 2013 Fla. App. LEXIS 12643

District Court of Appeal of Florida | Filed: Aug 14, 2013 | Docket: 60233513

Cited 1 times | Published

remedy does not preclude a declaratory judgment. § 86.111, Fla. Stat. Thus we are called upon to decide

Sehringer v. Big Lots, Inc.

532 F. Supp. 2d 1335, 2007 U.S. Dist. LEXIS 73859, 2007 WL 2908089

District Court, M.D. Florida | Filed: Oct 3, 2007 | Docket: 2195370

Cited 1 times | Published

complaint. (Doc. # 3 at 4-5). Florida Statute § 86.111 provides that "existence of another adequate remedy

Larry Darnell Springer, Sr., Individually, and as Trustee of The, Larry Darnell Springer, Sr. Trust v. Charlotte Miller Merricks

District Court of Appeal of Florida | Filed: Nov 27, 2024 | Docket: 69419599

Published

had been instituted as an action in chancery.” § 86.111, Fla. Stat. (2022). While the jury makes factual

MICHAEL A. MARKS, P.A. v. GEICO GENERAL INSURANCE COMPANY

District Court of Appeal of Florida | Filed: Jan 12, 2022 | Docket: 62218190

Published

argues this conclusion was in error, because section 86.111, Florida Statutes (2020), expressly provides:

Heritage Property and Casualty Insurance Co. v. Romanach

224 So. 3d 262, 2017 Fla. App. LEXIS 9985, 2017 WL 2960729

District Court of Appeal of Florida | Filed: Jul 12, 2017 | Docket: 6088810

Published

not preclude a judgment for declaratory relief.” § 86.111, Fla. Stat. (2015). 4 Conclusion

Green v. State Farm Mutual Automobile Insurance Co.

225 So. 3d 229, 2017 WL 2131492, 2017 Fla. App. LEXIS 7026

District Court of Appeal of Florida | Filed: May 17, 2017 | Docket: 60272427

Published

not preclude a judgment for declaratory relief.” § 86.111, Fla. Stat. (2015). As noted above, under section

Amber Reinforcing, Inc. v. Hubbard Construction Co.

801 So. 2d 314, 2001 Fla. App. LEXIS 17755, 2001 WL 1598777

District Court of Appeal of Florida | Filed: Dec 17, 2001 | Docket: 64810674

Published

complaint for declaratory judgment in accordance with § 86.111, Fla. Stat.” As grounds for reversal, Appellant

Metropolitan Dade County v. Sunlink Corp.

642 So. 2d 551, 1993 Fla. App. LEXIS 1283, 1992 WL 12109

District Court of Appeal of Florida | Filed: Feb 2, 1993 | Docket: 1529398

Published

(Fla. 1976); § 86.021, Fla. Stat. (1989); see § 86.111, Fla. Stat. (1989) ("The existence of another

Florida Industrial Commission v. Neal

224 So. 2d 774, 1969 Fla. App. LEXIS 5598

District Court of Appeal of Florida | Filed: Jun 24, 1969 | Docket: 64510578

Published

Atlantic Beach, (Fla.App.1965) 178 So.2d 906. .F.S. § 86.111, F.S.A. “The existence of another adequate remedy