Florida Statutes
Fla. Stat. § 171.031 (2025)
Definitions.
✓ 2025 Florida Statutes — current through the 2025 Regular Session
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171.031 Definitions.—As used in this chapter, the following words and terms have the following meanings unless some other meaning is plainly indicated:
(1) “Annexation” means the adding of real property to the boundaries of an incorporated municipality, such addition making such real property in every way a part of the municipality.
(2) “Compactness” means concentration of a piece of property in a single area and precludes any action which would create enclaves, pockets, or finger areas in serpentine patterns. Any annexation proceeding in any county in this state must be designed in such a manner as to ensure that the area will be reasonably compact.
(3) “Contiguous” means that a substantial part of a boundary of the territory sought to be annexed by a municipality is coterminous with a part of the boundary of the municipality. The separation of the territory sought to be annexed from the annexing municipality by a publicly owned county park; a right-of-way for a highway, road, railroad, canal, or utility; or a body of water, watercourse, or other minor geographical division of a similar nature, running parallel with and between the territory sought to be annexed and the annexing municipality, may not prevent annexation under this act, provided the presence of such a division does not, as a practical matter, prevent the territory sought to be annexed and the annexing municipality from becoming a unified whole with respect to municipal services or prevent their inhabitants from fully associating and trading with each other, socially and economically. However, nothing in this subsection may be construed to allow local rights-of-way, utility easements, railroad rights-of-way, or like entities to be annexed in a corridor fashion to gain contiguity; and when any provision of any special law prohibits the annexation of territory that is separated from the annexing municipality by a body of water or watercourse, then that law shall prevent annexation under this act.
(4) “Contraction” means the reversion of real property within municipal boundaries to an unincorporated status.
(5) “Enclave” means:
(a) Any unincorporated improved or developed area that is enclosed within and bounded on all sides by a single municipality; or
(b) Any unincorporated improved or developed area that is enclosed within and bounded by a single municipality and a natural or manmade obstacle that allows the passage of vehicular traffic to that unincorporated area only through the municipality.
(6) “Feasibility study” means an analysis conducted by qualified staff or consultants of the economic, market, technical, financial, and management feasibility of the proposed annexation or contraction, as applicable.
(7) “Municipality” means a municipality created pursuant to general or special law authorized or recognized pursuant to s. 2 or s. 6, Art. VIII of the State Constitution.
(8) “Newspaper of general circulation” means a newspaper printed in the language most commonly spoken in the area within which it circulates, which is readily available for purchase by all inhabitants in its area of circulation, but does not include a newspaper intended primarily for members of a particular professional or occupational group, a newspaper whose primary function is to carry legal notices, or a newspaper that is given away primarily to distribute advertising.
(9) “Parties affected” means any persons or firms owning property in, or residing in, either a municipality proposing annexation or contraction or owning property that is proposed for annexation to a municipality or any governmental unit with jurisdiction over such area.
(10) “Qualified voter” means any person registered to vote in accordance with law.
(11) “Sufficiency of petition” means the verification of the signatures and addresses of all signers of a petition with the voting list maintained by the county supervisor of elections and certification that the number of valid signatures represents the required percentage of the total number of qualified voters in the area affected by a proposed annexation.
(12) “Urban in character” means an area used intensively for residential, urban recreational or conservation parklands, commercial, industrial, institutional, or governmental purposes or an area undergoing development for any of these purposes.
(13) “Urban purposes” means that land is used intensively for residential, commercial, industrial, institutional, and governmental purposes, including any parcels of land retained in their natural state or kept free of development as dedicated greenbelt areas.
(14) “Urban services” means any services offered by a municipality, either directly or by contract, to any of its present residents.
History.—s. 1, ch. 74-190; s. 1, ch. 75-297; s. 75, ch. 81-259; s. 1, ch. 84-148; s. 15, ch. 93-206; s. 2, ch. 2023-305.
Notes of Decisions
Cited in 21
cases (1 in the last 5 years), 1981–2025 · leading case: Burton v. City of Belle Glade, 178 F.3d 1175 (11th Cir. 1999).
Burton v. City of Belle Glade, 178 F.3d 1175 (11th Cir. 1999). “74-190, § 1 (codified as amended at Fla. Stat. Ann. § 171.031 (11) (West 1987)).”
Burton v. City of Belle Glade, 966 F. Supp. 1178 (S.D. Fla. 1997). “Laws 93-206, codified at Fla. Stat. § 171.031 (13). But even if a roadway annexation would not create an enclave, it would nonetheless violate the compactness requirement.”
Cnty. of Volusia v. City of Deltona, 925 So. 2d 340 (Fla. 5th DCA 2006). “The circuit court departed from the essential requirements of the law in determining the property was contiguous.”
Martin Cnty. v. City of Stuart, 736 So. 2d 1264 (Fla. 4th DCA 1999). “The circuit court granted certiorari as to two of the parcels because they violated section 171.031(12), Florida Statutes, which precludes annexations which "would create enclaves, pockets, or finger areas in serpentine patterns," but denied certiorari as to the remaining…”
City of Sunrise v. Broward Cnty., 473 So. 2d 1387 (Fla. 4th DCA 1985). “Section 171.031(12), Florida Statutes (1983), defines "compactness" as: concentration of a piece of property in a single area and precludes any action which would create enclaves, pockets, or finger areas in serpentine patterns.”
City of Tallahassee v. Kovach, 733 So. 2d 576 (Fla. 1st DCA 1999). “This construction of section 171.031 is plainly erroneous. In annexation matters, section 171.”
City of Sanford v. Seminole Cnty., 538 So. 2d 113 (Fla. 5th DCA 1989). “§ 171.031(11), Fla. Stat. (1987). The City argues that the circuit court finding of lack of substantial contiguity adds an element not found in the statute, which requires only that the annexed property be contiguous.”
SCA Servs., ETC. v. City of Tallahassee, 418 So. 2d 1148 (Fla. 1st DCA 1982). “Section 171.031(5), Florida Statutes, defines "parties affected" as "any .”
Pinellas Cnty. v. City of Largo, 964 So. 2d 847 (Fla. 2d DCA 2007). “" § 171.031(12). And, of course, a charter county's method of voluntary municipal annexation must be consistent with the Act's purposes as expressed in section 171.”
City of Ctr. Hill v. McBryde, 952 So. 2d 599 (Fla. 5th DCA 2007). “" § 171.031(12), Fla. Stat. (2005). "Compactness" means the "concentration of a piece of property in a single area and precludes any action which would create enclaves, pockets, or finger areas in serpentine patterns.”
Levy v. Miami-Dade Cnty., 254 F. Supp. 2d 1269 (S.D. Fla. 2003). “VIII, §§ 2 & 6; Fla. Stat. § 171.031 , a county agency, Fla.”
City of Tampa v. Hillsborough Cnty., 504 So. 2d 10 (Fla. 2d DCA 1986). “§ 171.031(5). Additionally, Hillsborough County is the owner of 106.”
— 171.031(11) — 4 cases
Cnty. of Volusia v. City of Deltona, 925 So. 2d 340 (Fla. 5th DCA 2006). “The circuit court departed from the essential requirements of the law in determining the property was contiguous.”
Burton v. City of Belle Glade, 966 F. Supp. 1178 (S.D. Fla. 1997). “Laws 93-206, codified at Fla. Stat. § 171.031 (13). But even if a roadway annexation would not create an enclave, it would nonetheless violate the compactness requirement.”
City of Sanford v. Seminole Cnty., 538 So. 2d 113 (Fla. 5th DCA 1989). “§ 171.031(11), Fla. Stat. (1987). The City argues that the circuit court finding of lack of substantial contiguity adds an element not found in the statute, which requires only that the annexed property be contiguous.”
Bd. of Cnty. Com'rs v. City of Cocoa, 953 So. 2d 8 (Fla. 5th DCA 2007).
— 171.031(12) — 6 cases
Martin Cnty. v. City of Stuart, 736 So. 2d 1264 (Fla. 4th DCA 1999). “The circuit court granted certiorari as to two of the parcels because they violated section 171.031(12), Florida Statutes, which precludes annexations which "would create enclaves, pockets, or finger areas in serpentine patterns," but denied certiorari as to the remaining…”
City of Sunrise v. Broward Cnty., 473 So. 2d 1387 (Fla. 4th DCA 1985). “Section 171.031(12), Florida Statutes (1983), defines "compactness" as: concentration of a piece of property in a single area and precludes any action which would create enclaves, pockets, or finger areas in serpentine patterns.”
Burton v. City of Belle Glade, 966 F. Supp. 1178 (S.D. Fla. 1997). “Laws 93-206, codified at Fla. Stat. § 171.031 (13). But even if a roadway annexation would not create an enclave, it would nonetheless violate the compactness requirement.”
City of Ctr. Hill v. McBryde, 952 So. 2d 599 (Fla. 5th DCA 2007). “" § 171.031(12), Fla. Stat. (2005). "Compactness" means the "concentration of a piece of property in a single area and precludes any action which would create enclaves, pockets, or finger areas in serpentine patterns.”
Pinellas Cnty. v. City of Largo, 964 So. 2d 847 (Fla. 2d DCA 2007). “" § 171.031(12). And, of course, a charter county's method of voluntary municipal annexation must be consistent with the Act's purposes as expressed in section 171.”
— 171.031(2) — 1 case
Pinellas Cnty. v. City of Largo, 964 So. 2d 847 (Fla. 2d DCA 2007). “" § 171.031(12). And, of course, a charter county's method of voluntary municipal annexation must be consistent with the Act's purposes as expressed in section 171.”
— 171.031(5) — 9 cases
City of Tallahassee v. Kovach, 733 So. 2d 576 (Fla. 1st DCA 1999). “This construction of section 171.031 is plainly erroneous. In annexation matters, section 171.”
SCA Servs., ETC. v. City of Tallahassee, 418 So. 2d 1148 (Fla. 1st DCA 1982). “Section 171.031(5), Florida Statutes, defines "parties affected" as "any .”
City of Sunrise v. Broward Cnty., 473 So. 2d 1387 (Fla. 4th DCA 1985). “Section 171.031(12), Florida Statutes (1983), defines "compactness" as: concentration of a piece of property in a single area and precludes any action which would create enclaves, pockets, or finger areas in serpentine patterns.”
City of Tampa v. Hillsborough Cnty., 504 So. 2d 10 (Fla. 2d DCA 1986). “§ 171.031(5). Additionally, Hillsborough County is the owner of 106.”
SCA Servs. of Florida, Inc. v. City of Tallahassee, 393 So. 2d 35 (Fla. 1st DCA 1981).
— 171.031(6) — 1 case
West Villagers for Responsible Gov't, Inc., Meisel v. City of North Port, Florida (Fla. 2d DCA 2025).
— 171.031(8) — 1 case
May v. Lee Cnty., 483 So. 2d 481 (Fla. 2d DCA 1986).
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