The 2023 Florida Statutes
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The defendant property owners based their objection to Royal Palm's expert on the provisions of section 475.611, which distinguishes between a “certified general appraiser” and a “certified residential appraiser.” However, that distinction is immaterial because section 475.612(4) provides as follows: “This section does not prevent any state court or administrative law judge from certifying as an expert witness in any legal or administrative proceeding an appraiser who is not certified, licensed, or registered; nor does it prevent any appraiser from testifying, with respect to the results of an appraisal.”
The requirement that the taking authority's estimate of value be based on a "valid appraisal" was established by the enactment of section 74.031 in 1965 and has never been modified. See § 74.031, Fla. Stat. (2000); Ch. 65-369, § 4, at 1279-80, Laws of Fla. Part II of chapter 475, authorizing the certification and licensing of real estate appraisers, was created in 1991 and substantially revised in 1998. See Ch. 91-89, § 9 at 674-86, Laws of Fla.; Ch. 98-250 §§ 20-38 at 2209-20, Laws of Fla. We do not believe that when the Legislature wrote section 74.031, it intended to incorporate or refer to a statute that was not created until 26 years later. To the contrary, section 475.612(4), Florida Statutes (1999) addresses the admissibility of the expert testimony from appraisers who are not licensed, certified or registered and provides:
. . . However, that distinction is immaterial because section 475.612(4) provides as follows: “This section . . .
. . . To the contrary, section 475.612(4), Florida Statutes (1999) addresses the admissibility of the expert . . .