Florida Statutes
Fla. Stat. § 95.22 (2025)
Limitation upon claims by remaining heirs, when deed made by one or more.
✓ 2025 Florida Statutes — current through the 2025 Regular Session
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95.22 Limitation upon claims by remaining heirs, when deed made by one or more.—
(1) When any person owning real property or any interest in it dies and a conveyance is made by one or more of the person’s heirs or devisees, purporting to convey, either singly or in the aggregate, the entire interest of the decedent in the property or any part of it, then no person shall claim or recover the property conveyed after 7 years from the date of recording the conveyance in the county where the property is located.
(2) This section shall not apply to persons whose names appear of record as devisees under the will or as the heirs in proceedings brought to determine their identity in the office of the judge administering the estate of decedent.
History.—s. 1, ch. 10168, 1925; CGL 4659; s. 14, ch. 20954, 1941; s. 15, ch. 73-334; s. 16, ch. 74-382; s. 526, ch. 95-147.
Notes of Decisions
Cited in 10
cases (1 in the last 5 years), 1954–2023 · leading case: Morgan v. Amerada Hess Corp., 357 So. 2d 1040 (Fla. 1st DCA 1978).
Morgan v. Amerada Hess Corp., 357 So. 2d 1040 (Fla. 1st DCA 1978). “Appellee next contends that this action is barred by § 95.22, Florida Statutes (1975). “Limitation upon claims by remaining heirs, when deed made by one or more.”
Morrison v. Byrd, 72 So. 2d 657 (Fla. 1954). ““It appears by the evidence that the original owner through whom plaintiffs claim died in 1933, prior to the effective date of F.S. § 95.22 [F.S.A.] which contains a provision to the effect that the seven year statute of limitations mentioned in the first paragraph of the…”
Ray v. Rotella, 425 So. 2d 94 (Fla. 5th DCA 1982). “Such deeds of distribution may also benefit the record title as the basis for limitations (see §§ 95.22 and 95.231, Fla.Stat. (1981)). Carefully worded recitals of facts relating to heirship inserted in such deeds can also become admissible and prima facie evidence of essential…”
Creary v. Est. of Creary, 338 So. 2d 26 (Fla. 1st DCA 1976). “The trial judge held appellant’s claim to have been barred by F.S. 95.22, F.S.1969 and F.S. 95.23, F.S.”
Brown v. Floyd, 202 So. 2d 215 (Fla. 1st DCA 1967). “The defendant-appellant, in support of his claim that he has a good title to the East half of the SE 14 of Section 13, Township 8 South, Range 16 East, cites F.S. § 95.22 as a bar to the appellee plaintiffs action: F.”
Vaughn v. Vaughn, 119 So. 2d 391 (Fla. 2d DCA 1960). “1927 [F.S.A. § 95.22], op *395 erate as bar to the recovery by the complainants.”
Leila Williams, Etc. v. Barbara Williams (Fla. 3d DCA 2023). “The record contains no allegation of procedural irregularities, fraud, or bad faith. Finding no error with the trial court’s determination, we affirm the dismissal.”
Race v. Moseley, 308 So. 2d 137 (Fla. 2d DCA 1975). “Yet, for purposes of § 95.16, we cannot tell whether this status existed for more than seven years prior to the time this suit was filed.”
Egger v. Egger, 506 So. 2d 1168 (Fla. 3d DCA 1987). “Plaintiffs appeal the trial court's finding which quieted title to Lots 5 and 6 in Mary pursuant to section 95.22, Florida Statutes (1985). 3 Plaintiffs argue, and we agree, that section 95.”
Purvis v. United Parcel Serv., 643 So. 2d 1161 (Fla. 1st DCA 1994). “” 4 Arthur Larson, Law of Workmens’ Compensation § 95.22, at 17-126 (1994). Applying the above test to the facts in the instant case, I find no support for the conclusion that claimant’s second injury was but an exacerbation of the earlier injury, because nothing in the record…”
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