Florida Statutes

Fla. Stat. § 95.14 (2025)

Real property actions; limitation upon action founded upon title.

✓ 2025 Florida Statutes — current through the 2025 Regular Session

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95.14 Real property actions; limitation upon action founded upon title.—No cause of action or defense to an action founded on the title to real property, or to rents or service from it, shall be maintained unless:

(1) The person prosecuting the action or making the defense, or under whose title the action is prosecuted or the defense is made, or the ancestor, predecessor, or grantor of the person, was seized or possessed of the real property within 7 years before commencement of the action; or

(2) Title to the real property was derived from the United States or the state within 7 years before commencement of the action. The time under this subsection shall not begin to run until the conveyance of the title from the state or the United States.

History.—s. 3, ch. 1869, 1872; RS 1288; GS 1719; RGS 2933; CGL 4653; s. 10, ch. 74-382.

Notes of Decisions

Cited in 7 cases, 1954–1994 · leading case: Moore v. Musa, 198 So. 2d 843 (Fla. 3d DCA 1967).

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Moore v. Musa, 198 So. 2d 843 (Fla. 3d DCA 1967). · cites it 3× “The answer alleged, among other things, adverse possession under color of title and that the action was barred by the statute of limitations, § 95.14 Fla. Stat., F.S.A. [3] The court granted a motion for summary judgment on the ground that the action was barred by the statute of…”

Sarasota Cnty. v. Ex, 645 So. 2d 7 (Fla. 2d DCA 1994). · cites it 2× “§ 95.14, Fla. Stat. (1991). This statute, which governs actions founded on title to real property, or to rents or service from it, would bar the Exes' action, filed more than eight years after they transferred title to the county.”

Bd. of Trs. of Int. v. Stevens, 472 So. 2d 1287 (Fla. 2d DCA 1985). · cites it 2× “See also, § 95.14, Fla. Stat.; 2 Fla.Jur.2d Adverse Possession § 60.”

Atl. Land & Improvement Co. v. Davis, 70 So. 2d 910 (Fla. 1954). · cites it 2× “” For a further defense Davis" alleged that appellants had not “been seized or possessed of said premises within seven years before the accruing of the supposed right of action upon which suit is brought and that said plaintiffs are barred from the bringing of this proceeding…”

Comerica Trust Co. of Florida, N.A. v. Monroe Cnty., 622 So. 2d 1023 (Fla. 3d DCA 1993). · cites it 2× “§ 95.14, Fla.Stat. (1989); § 689.18(4), Fla.”

Kelley v. City of Cocoa, 188 So. 2d 71 (Fla. Dist. Ct. App. 1966). · cites it 2× “At that time there was either a breach of the contractual covenant or a termination of the grantee’s estate with the right of possession vested in the grantors or their heirs and after seven years their cause of action was barred by F.S.A. § 95.14, 54 C.J.S. Limitations of…”

Grizzard v. City of Leesburg, 34 Fla. Supp. 58 (Fla. Cir. Ct., Lake Cty. 1970). “, as to the claim for damages; (5) the statute of limitations, §95.14, F.S., for the recovery of possession of property in possession of another.”

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