Florida Statute 95.22 - Full Text and Legal Analysis

The 2025 Florida Statutes

Title VIII
LIMITATIONS

Chapter 95
LIMITATIONS OF ACTIONS; ADVERSE POSSESSION

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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.

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Amendments to 95.22

Annotations, Discussions, Cases:

Cases Citing Statute 95.22

Total Results: 35

Overland Const. Co., Inc. v. Sirmons

369 So. 2d 572

Supreme Court of Florida | Filed: Mar 1, 1979 | Docket: 470751

Cited 86 times | Published

been filed. Moreover, the savings clause of section 95.022[10] extended the deadline for instituting existing

Bauld v. JA Jones Const. Co.

357 So. 2d 401, 1978 Fla. LEXIS 4729

Supreme Court of Florida | Filed: Mar 9, 1978 | Docket: 453773

Cited 67 times | Published

termination or completion of the contract. Section 95.022 provides that the revisions became effective

Universal Engineering Corp. v. Perez

451 So. 2d 463, 1984 Fla. LEXIS 3026

Supreme Court of Florida | Filed: May 17, 1984 | Docket: 1483313

Cited 31 times | Published

also contained a savings clause, codified as section 95.022, Florida Statutes (1975), which provided: This

Lamb Ex Rel. Donaldson v. Volkswagenwerk Aktienge-Sellschaft

631 F. Supp. 1144, 1986 U.S. Dist. LEXIS 27707

District Court, S.D. Florida | Filed: Mar 25, 1986 | Docket: 1784016

Cited 22 times | Published

statute was accompanied by a savings clause, Section 95.022, which extended by one year the deadline for

Alford v. Summerlin

423 So. 2d 482

District Court of Appeal of Florida | Filed: Dec 14, 1982 | Docket: 544497

Cited 21 times | Published

by that date, the action shall be barred." Section 95.022, Florida Statutes (Supp. 1974). It is immediately

Purk v. Federal Press Co.

387 So. 2d 354

Supreme Court of Florida | Filed: Jul 24, 1980 | Docket: 1355265

Cited 18 times | Published

been filed. Moreover, the savings clause of section 95.022 extended the deadline for instituting existing

Homemakers, Inc. v. Gonzales

400 So. 2d 965

Supreme Court of Florida | Filed: Jul 2, 1981 | Docket: 1677228

Cited 16 times | Published

commenced by that date, the action shall be barred. § 95.022, Fla. Stat. (Supp. 1974). Finally, the statute

Brooks v. Cerrato

355 So. 2d 119

District Court of Appeal of Florida | Filed: Jan 24, 1978 | Docket: 1360603

Cited 16 times | Published

law may be commenced before January 1, 1976. Section 95.022, Florida Statutes (Supp. 1974). The plaintiff

Carpenter v. Florida Cent. Credit Union

369 So. 2d 935

Supreme Court of Florida | Filed: Feb 22, 1979 | Docket: 470922

Cited 12 times | Published

date to file suit and preserve their rights. Section 95.022, Florida Statutes (1975). The very nature of

Perez v. Universal Engineering Corp.

413 So. 2d 75

District Court of Appeal of Florida | Filed: Mar 30, 1982 | Docket: 1345003

Cited 11 times | Published

administered without sale, denial or delay. [4] Section 95.022 entitled "Effective date; saving clause" provides:

Boyce v. Cluett

672 So. 2d 858, 1996 WL 148174

District Court of Appeal of Florida | Filed: Apr 3, 1996 | Docket: 1764151

Cited 8 times | Published

argue was in effect as of January 1, 1975 (see section 95.022), and at the time the alleged abuse occurred

Worrell v. John F. Kennedy Mem. Hosp.

384 So. 2d 897

District Court of Appeal of Florida | Filed: May 28, 1980 | Docket: 1678431

Cited 7 times | Published

malpractice cases and that the saving clause (Section 95.022) was no indication of a retroactive intent

CATES EX REL. CATES v. Graham

427 So. 2d 290

District Court of Appeal of Florida | Filed: Feb 22, 1983 | Docket: 1478080

Cited 6 times | Published

revised statutes contained a "savings clause," section 95.022, Florida Statutes (1975), which provided a

Pullum v. Cincinnati, Inc.

458 So. 2d 1136

District Court of Appeal of Florida | Filed: Sep 26, 1984 | Docket: 2521991

Cited 5 times | Published

575. [5] This savings clause was codified as Section 95.022, Florida Statutes (1975). [6] Section 95.11(4)(b)

Ruhl v. Perry

390 So. 2d 353

Supreme Court of Florida | Filed: Nov 13, 1980 | Docket: 1750170

Cited 5 times | Published

sealed note from twenty years to five years. Section 95.022, enacted as part of the same legislative act

Amerada Hess Corp. v. Morgan

426 So. 2d 1122

District Court of Appeal of Florida | Filed: Feb 3, 1983 | Docket: 1683696

Cited 4 times | Published

expiration of the saving clause provided in Section 95.022, Florida Statutes (1975). The McMillans' interest

Meir v. KIRK, PINKERTON, McCLELLAND, SAVARY & CARR, PA

561 So. 2d 399, 1990 WL 60902

District Court of Appeal of Florida | Filed: May 9, 1990 | Docket: 1480926

Cited 3 times | Published

11(4)(a), it also enacted a savings clause, section 95.022, providing that "[t]his act shall become effective

Jones v. Rainey

386 So. 2d 1319

District Court of Appeal of Florida | Filed: Sep 5, 1980 | Docket: 194074

Cited 3 times | Published

law could be commenced before January 1, 1976. § 95.022, Fla. Stat. (1979). Appellant did not commence

Wetmore v. Brennan

378 So. 2d 79

District Court of Appeal of Florida | Filed: Dec 18, 1979 | Docket: 1795630

Cited 3 times | Published

occurs. Section 36 of Chapter 74-382 codified as Section 95.022, Florida Statutes (1975) provided an effective

MacRae v. Cessna Aircraft Co.

457 So. 2d 1093, 9 Fla. L. Weekly 2078, 1984 Fla. App. LEXIS 15252

District Court of Appeal of Florida | Filed: Sep 27, 1984 | Docket: 426328

Cited 2 times | Published

court held that because the savings clause of § 95.022, Fla. Stat. extended by one year the deadline

Egger v. Egger

506 So. 2d 1168, 12 Fla. L. Weekly 1235, 1987 Fla. App. LEXIS 8220

District Court of Appeal of Florida | Filed: May 12, 1987 | Docket: 64627029

Cited 1 times | Published

pursuant to section 95.22, Florida Statutes (1985).3 Plaintiffs argue, and we agree, that section 95.22 is not

Durring v. Reynolds, Smith & Hills

471 So. 2d 603, 10 Fla. L. Weekly 1545

District Court of Appeal of Florida | Filed: Jun 18, 1985 | Docket: 1724652

Cited 1 times | Published

Section 36, later codified in Florida Statutes as section 95.022, provided: This act shall become effective

LEILA WILLIAMS, etc. v. BARBARA WILLIAMS

District Court of Appeal of Florida | Filed: Jan 18, 2023 | Docket: 66738034

Published

(determining that the statute of limitations in section 95.22, Florida Statutes (1985) doesn’t bar an action

Purvis v. United Parcel Service

643 So. 2d 1161, 1994 Fla. App. LEXIS 9660, 1994 WL 549475

District Court of Appeal of Florida | Filed: Oct 11, 1994 | Docket: 64751502

Published

4 Arthur Larson, Law of Workmens’ Compensation § 95.22, at 17-126 (1994). Applying the above test to the

Lugo v. Ford Motor Co.

611 F. Supp. 789, 1985 U.S. Dist. LEXIS 18790

District Court, S.D. Florida | Filed: Jun 18, 1985 | Docket: 66165851

Published

in 1974. Chapter 74-382, Laws of Florida. Section 95.022 provides that the revision became effective

Maiden v. Cogdill

428 So. 2d 376, 1983 Fla. App. LEXIS 19314

District Court of Appeal of Florida | Filed: Mar 23, 1983 | Docket: 64595766

Published

years. Chapter 74-382, Laws of Florida 1974. Section 95.022 was added to provide a saving clause; viz,

Cates ex rel. Cates v. Graham

427 So. 2d 290, 1983 Fla. App. LEXIS 18710

District Court of Appeal of Florida | Filed: Feb 22, 1983 | Docket: 64595271

Published

revised statutes contained a “savings clause,” section 95.022, Florida Statutes (1975), which provided a

Garofalo v. Community Hospital of South Broward

382 So. 2d 722, 1980 Fla. App. LEXIS 15655

District Court of Appeal of Florida | Filed: Mar 5, 1980 | Docket: 64575622

Published

professional. A saving clause was also provided in Section 95.022, Florida Statutes (Supp.1974) as follows: 95

Morgan v. Amerada Hess Corp.

357 So. 2d 1040, 1978 Fla. App. LEXIS 15792

District Court of Appeal of Florida | Filed: Apr 6, 1978 | Docket: 64564070

Published

Florida, but with a savings clause contained in § 95.022, Florida Statutes (1975), which would be applicable

Nash v. Asher

342 So. 2d 1038, 1977 Fla. App. LEXIS 15095

District Court of Appeal of Florida | Filed: Feb 18, 1977 | Docket: 64557293

Published

provided by Section 95.022 Florida Statutes, 1975 applies to the present case. Section 95.022 Florida Statutes

Creary v. Estate of Creary

338 So. 2d 26, 1976 Fla. App. LEXIS 15543

District Court of Appeal of Florida | Filed: Jul 19, 1976 | Docket: 64555352

Published

to have been barred by F.S. 95.22, F.S.1969 and F.S. 95.23, F.S.1969. F.S. 95.22, F.S.1969, provides: “When

Race v. Moseley

308 So. 2d 137, 1975 Fla. App. LEXIS 14492

District Court of Appeal of Florida | Filed: Feb 19, 1975 | Docket: 64544486

Published

that her title is perfected by reason of either § 95.22 or § 95.23 is untenable. Reed v. Fain, Fla.1961

Brown v. Floyd

202 So. 2d 215, 1967 Fla. App. LEXIS 4280

District Court of Appeal of Florida | Filed: Aug 3, 1967 | Docket: 64502284

Published

16 East, cites F.S. § 95.22 as a bar to the appellee plaintiffs action: F.S. § 95.22, F.S.A. reads as follows:

Vaughn v. Vaughn

119 So. 2d 391, 1960 Fla. App. LEXIS 2456

District Court of Appeal of Florida | Filed: Apr 5, 1960 | Docket: 60194645

Published

Acts of 1925, section 4659, C.G.L.1927 [F.S.A. § 95.22], op*395erate as bar to the recovery by the complainants

Morrison v. Byrd

72 So. 2d 657, 1954 Fla. LEXIS 1424

Supreme Court of Florida | Filed: May 11, 1954 | Docket: 64485541

Published

died in 1933, prior to the effective date of F.S. § 95.22 [F.S.A.] which contains a provision to the effect

This Florida statute resource is curated by Graham W. Syfert, Esq., a Jacksonville, Florida personal injury and workers' compensation attorney. Attorney Syfert regularly works with Chapter 95 in the context of civil statutes of limitations and represents clients throughout Northeast Florida. For legal consultation, call 904-383-7448.