Florida Statutes
Fla. Stat. § 222.14 (2025)
Exemption of cash surrender value of life insurance policies and annuity contracts from legal process.
✓ 2025 Florida Statutes — current through the 2025 Regular Session
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222.14 Exemption of cash surrender value of life insurance policies and annuity contracts from legal process.—The cash surrender values of life insurance policies issued upon the lives of citizens or residents of the state and the proceeds of annuity contracts issued to citizens or residents of the state, upon whatever form, shall not in any case be liable to attachment, garnishment or legal process in favor of any creditor of the person whose life is so insured or of any creditor of the person who is the beneficiary of such annuity contract, unless the insurance policy or annuity contract was effected for the benefit of such creditor.
Notes of Decisions
Cited in 105
cases (2 in the last 5 years), 1954–2024 · leading case: In Re Allen, 203 B.R. 786 (Bankr. M.D. Fla. 1996).
In Re Allen, 203 B.R. 786 (Bankr. M.D. Fla. 1996). “EXEMPTIONS UNDER FLORIDA STATUTES GW also objects to the Debtor’s claim of exemptions of payments received from certain annuity contracts and cash surrender value of a life insurance policy on the ground that they do not meet requirements of Fla.Stat. § 222.14. Section 222.14…”
In Re McCollam, 612 So. 2d 572 (Fla. 1993). “We hold that section 222.14, Florida Statutes (1989), exempts an annuity from creditor claims in bankruptcy.”
Goldenberg v. Sawczak, 791 So. 2d 1078 (Fla. 2001). “" Sawczak claimed that the cash surrender value of these policies were not exempt under section 222.14, Florida Statutes (1995), because moneys received from the exercise of a surrender provision are not proceeds.”
Bank Leumi Trust Co. of New York v. Lang, 898 F. Supp. 883 (S.D. Fla. 1995). “2 Fla.Stat. § 222.14. In September 1990, Bank Leumi filed a motion for Summary Judgment in the District of New Jersey.”
In Re Pizzi, 153 B.R. 357 (Bankr. S.D. Florida 1993). “Fla.Stat. § 222.14 is controlling. In relevant part, § 222.”
Marie v. Green (In Re Green), 268 B.R. 628 (Bankr. M.D. Fla. 2001). “Fla. Stat. § 222.14 (2000). 222.21. Exemption of pension money and retirement or profit-sharing benefits from legal processes (2)(a) Except as provided in paragraph (b), any money or other assets payable to a participant or beneficiary from, or any interest of any participant or…”
In Re Dillon, 166 B.R. 766 (Bankr. S.D. Florida 1994). “, provides in pertinent part: [T]he proceeds of annuity contracts issued to citizens or residents of the state, upon whatever form, shall not in any case be liable to attachment, garnishment or legal process in favor .”
In Re Seilkop, 107 B.R. 776 (Bankr. S.D. Florida 1989). “The debtor filed for relief under Chapter 7 of the Bankruptcy Code and listed as exempt an annuity contract under Fla.Stat. § 222.14 and a pension plan under Fla.”
Solomon v. Guardian Life Ins. Co. of Am., 186 B.R. 535 (S.D. Fla. 1995). “Fla.Stat. § 222.14. In his Schedule C of exempt property Solomon listed the following: “structured settlement annuity received as settlement of a 1984 lawsuit .”
In Re Allen, 217 B.R. 945 (Bankr. M.D. Fla. 1998). “§ 222.14 Fla. Statutes Annuity Metropolitan Life Ins.”
Ruff v. Dixson (In Re Dixson), 153 B.R. 594 (Bankr. M.D. Fla. 1993). “On January 28, 1993, the Florida Supreme Court answered the question affirmatively, holding that “section 222.14, Florida Statutes (1989), exempts an annuity from creditor claims in bankruptcy.”
Rutland v. Petersen (In Re Petersen), 323 B.R. 512 (Bankr. N.D. Fla. 2005). “59, was properly listed as an asset on Schedule B and exempted on Schedule C pursuant to Fla. Stat. § 222.14 , without objection. She stated that she did not earn any interest or other money on the money she had in the annuity, and argues that absent such earnings on capital…”
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