Florida Statutes

Fla. Stat. § 194.171 (2025)

Circuit court to have original jurisdiction in tax cases.

✓ 2025 Florida Statutes — current through the 2025 Regular Session

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194.171 Circuit court to have original jurisdiction in tax cases.—

(1) The circuit courts have original jurisdiction at law of all matters relating to property taxation. Venue is in the county where the property is located, except that venue shall be in Leon County when the property is assessed pursuant to s. 193.085(4).

¹(2)(a) No action shall be brought to contest a tax assessment after 60 days from the date the assessment being contested is certified for collection under s. 193.122(2), or after 60 days from the date a decision is rendered concerning such assessment by the value adjustment board if a petition contesting the assessment had not received final action by the value adjustment board prior to extension of the roll under s. 197.323.

(b) Notwithstanding paragraph (a), the taxpayer that received a final action by the value adjustment board may bring an action within 30 days after recertification by the property appraiser under s. 193.122(3) if the roll was extended pursuant to s. 197.323.

(3) Before an action to contest a tax assessment may be brought, the taxpayer shall pay to the collector not less than the amount of the tax which the taxpayer admits in good faith to be owing. The collector shall issue a receipt for the payment, and the receipt shall be filed with the complaint. Notwithstanding the provisions of chapter 197, payment of the taxes the taxpayer admits to be due and owing and the timely filing of an action pursuant to this section shall suspend all procedures for the collection of taxes prior to final disposition of the action.

(4) Payment of a tax shall not be deemed an admission that the tax was due and shall not prejudice the right to bring a timely action as provided in subsection (2) to challenge such tax and seek a refund.

(5) No action to contest a tax assessment may be maintained, and any such action shall be dismissed, unless all taxes on the property assessed in years after the action is brought, which the taxpayer in good faith admits to be owing, are paid before they become delinquent.

(6) The requirements of subsections (2), (3), and (5) are jurisdictional. No court shall have jurisdiction in such cases until after the requirements of both subsections (2) and (3) have been met. A court shall lose jurisdiction of a case when the taxpayer has failed to comply with the requirements of subsection (5).

History.—s. 1, ch. 8586, 1921; CGL 1038; s. 2, ch. 29737, 1955; s. 1, ch. 67-538; ss. 1, 2, ch. 69-55; s. 8, ch. 69-102; s. 6, ch. 69-140; ss. 30, 31, ch. 70-243; s. 1, ch. 72-239; s. 6, ch. 74-234; s. 17, ch. 82-226; s. 7, ch. 83-204; s. 56, ch. 83-217; s. 211, ch. 85-342; s. 3, ch. 88-146; s. 151, ch. 91-112; s. 32, ch. 94-353; s. 1470, ch. 95-147; s. 11, ch. 2025-208.

¹Note.—Section 12, ch. 2025-208, provides that “[t]he amendments made by this act to s. 194.171, Florida Statutes, first apply to the 2026 tax roll.”

Note.—Former ss. 192.21, 194.151, 196.01.

Notes of Decisions

Cited in 212 cases (9 in the last 5 years), 1971–2026 · leading case: Cason v. Florida Dept. of Mgmt. Servs., 944 So. 2d 306 (Fla. 2006).

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Cason v. Florida Dept. of Mgmt. Servs., 944 So. 2d 306 (Fla. 2006). · cites it 48× “171 is part of a "comprehensive statutory scheme for counties to assess and collect taxes simultaneously with procedures for taxpayer challenges to tax assessments.”

Genesis Ministries, Inc. v. Gregory S. Brown, as Prop. etc., 186 So. 3d 1074 (Fla. 1st DCA 2016). · cites it 39× “Section 194.171 does not refer to section 196.”

Markham v. Neptune Hollywood Beach Club, 527 So. 2d 814 (Fla. 1988). · cites it 20× “The Gulfside court based its decision on the "plain meaning" of subsection (6) of section 194.171 which was added to that section by chapter 83-204, section 7, Laws of Florida.”

Miles v. Parrish, 199 So. 3d 1046 (Fla. 4th DCA 2016). · cites it 17× “The trial court dismissed her complaint for lack of jurisdiction, ruling that it had been filed beyond the sixty-day statute of non-claim under section 194.171, Florida Statutes. We find this was error and reverse.”

Ward v. Brown, 892 So. 2d 1059 (Fla. 1st DCA 2003). · cites it 15× “Appellants argue they were not subject to the 60 day time limits contained in section 194.171, Florida Statutes, because rather than challenging the assessment on the particular piece of property, they are challenging the classification placed on the property by the assessor.”

Miller v. Nolte, 453 So. 2d 397 (Fla. 1984). · cites it 13× “The property appraiser filed a motion to dismiss the complaint alleging, among other things, that the statute of limitations, section 194.171(2), Florida Statutes (1981), prohibited taxpayer's suit.”

State, Dept. of Revenue v. Stafford, 646 So. 2d 803 (Fla. 4th DCA 1994). · cites it 16× “We grant the petition for writ of prohibition because respondent FDIC did not comply with the jurisdictional requirements of section 194.171, Florida Statutes (1993), governing challenges to property tax assessments.”

Wal-Mart Stores, Inc. v. Day, 742 So. 2d 408 (Fla. 5th DCA 1999). · cites it 23× “appeals from a final judgment which determined that its lawsuit challenging a 1997 tax assessment of property in two stores located in Osceola County was untimely under section 194.171, Florida Statutes (1997).”

Bystrom v. Diaz, 514 So. 2d 1072 (Fla. 1987). · cites it 7× “The trial court dismissed the action with prejudice under subsections 194.”

Higgs v. Armada Key West Ltd. P'ship, 903 So. 2d 303 (Fla. 3d DCA 2005). · cites it 15× “Section 194.171 of the Florida Statutes confers jurisdiction on the circuit courts to hear ad valorem tax assessment contests and authorizes such contests (1) if brought within sixty days of the date the contested assessment is certified for collection or from a decision by a…”

Davis v. MacEdonia Hous. Auth., 641 So. 2d 131 (Fla. 1st DCA 1994). · cites it 14× “194, Florida Statutes (1991), a taxpayer may request an informal conference with the property appraiser and/or may timely petition the value adjustment board to reverse the denial of exemption, and may thereafter bring an action in circuit court to contest the board's action, so…”

Vill. of Doral Place Ass'n v. RU4 Real, Inc., 22 So. 3d 627 (Fla. 3d DCA 2009). · cites it 7× “See § 194.171(2), Fla. Stat. (2003). The court granted declaratory relief, holding that when the Buyers bought Tract F at the public sale, the Buyers took the property subject to the already existing condominium declaration, and that the Association and unit owners are entitled…”

Show all 212 citing cases →

— 194.171(1) — 16 cases

Ward v. Brown, 892 So. 2d 1059 (Fla. 1st DCA 2003). “Appellants argue they were not subject to the 60 day time limits contained in section 194.171, Florida Statutes, because rather than challenging the assessment on the particular piece of property, they are challenging the classification placed on the property by the assessor.”

Willens v. Garcia, 53 So. 3d 1113 (Fla. 3d DCA 2011).

De La Mora v. Andonie, 51 So. 3d 517 (Fla. 3d DCA 2010).

Higgs v. Armada Key West Ltd. P'ship, 903 So. 2d 303 (Fla. 3d DCA 2005). “Section 194.171 of the Florida Statutes confers jurisdiction on the circuit courts to hear ad valorem tax assessment contests and authorizes such contests (1) if brought within sixty days of the date the contested assessment is certified for collection or from a decision by a…”

Bruner v. Hartsfield, 23 So. 3d 192 (Fla. 1st DCA 2009).

— 194.171(2) — 97 cases

Genesis Ministries, Inc. v. Gregory S. Brown, as Prop. etc., 186 So. 3d 1074 (Fla. 1st DCA 2016). “Section 194.171 does not refer to section 196.”

Cason v. Florida Dept. of Mgmt. Servs., 944 So. 2d 306 (Fla. 2006). “171 is part of a "comprehensive statutory scheme for counties to assess and collect taxes simultaneously with procedures for taxpayer challenges to tax assessments.”

Miles v. Parrish, 199 So. 3d 1046 (Fla. 4th DCA 2016). “The trial court dismissed her complaint for lack of jurisdiction, ruling that it had been filed beyond the sixty-day statute of non-claim under section 194.171, Florida Statutes. We find this was error and reverse.”

Markham v. Neptune Hollywood Beach Club, 527 So. 2d 814 (Fla. 1988). “The Gulfside court based its decision on the "plain meaning" of subsection (6) of section 194.171 which was added to that section by chapter 83-204, section 7, Laws of Florida.”

Miller v. Nolte, 453 So. 2d 397 (Fla. 1984). “The property appraiser filed a motion to dismiss the complaint alleging, among other things, that the statute of limitations, section 194.171(2), Florida Statutes (1981), prohibited taxpayer's suit.”

— 194.171(3) — 24 cases

Genesis Ministries, Inc. v. Gregory S. Brown, as Prop. etc., 186 So. 3d 1074 (Fla. 1st DCA 2016). “Section 194.171 does not refer to section 196.”

Millstream Corp. v. Dade Cnty., 340 So. 2d 1276 (Fla. 3d DCA 1977).

Blake v. RMS Holding Corp., 341 So. 2d 795 (Fla. 3d DCA 1977).

— 194.171(3)(4) — 1 case

GBB Investments, Inc. v. Hinterkopf, 343 So. 2d 899 (Fla. 3d DCA 1977).

— 194.171(4) — 5 cases

North Port Bank v. State, Dep't of Revenue, 313 So. 2d 683 (Fla. 1975).

State, Dept. of Revenue v. Markham, 426 So. 2d 555 (Fla. 4th DCA 1982).

Bystrom v. Equitable Life Assurance Soc'y of United States, 416 So. 2d 1133 (Fla. 3d DCA 1982).

Bystrom v. Equitable Life Assur. Soc., Etc., 416 So. 2d 1133 (Fla. 3d DCA 1982).

Palm Springs Mile Assocs., Ltd. v. Robbins, 43 Fla. Supp. 2d 158 (Fla. Cir. Ct. 1989).

— 194.171(5) — 19 cases

Genesis Ministries, Inc. v. Gregory S. Brown, as Prop. etc., 186 So. 3d 1074 (Fla. 1st DCA 2016). “Section 194.171 does not refer to section 196.”

Bystrom v. Diaz, 514 So. 2d 1072 (Fla. 1987). “The trial court dismissed the action with prejudice under subsections 194.”

Washington Square Corp. v. Wright, 687 So. 2d 1374 (Fla. 1st DCA 1997).

Forest Brooke/Hillsborough, LLC v. Henriquez, 194 So. 3d 1091 (Fla. 2d DCA 2016).

— 194.171(6) — 30 cases

Genesis Ministries, Inc. v. Gregory S. Brown, as Prop. etc., 186 So. 3d 1074 (Fla. 1st DCA 2016). “Section 194.171 does not refer to section 196.”

Thomas v. Smith, 882 So. 2d 1037 (Fla. 2d DCA 2004).

Reinish v. Clark, 765 So. 2d 197 (Fla. 1st DCA 2000).

— 194.171(8) — 1 case

Forest Brooke/Hillsborough, LLC v. Henriquez, 194 So. 3d 1091 (Fla. 2d DCA 2016).

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