Florida Statutes

Fla. Stat. § 682.14 (2025)

Modification or correction of award.

✓ 2025 Florida Statutes — current through the 2025 Regular Session

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682.14 Modification or correction of award.—

(1) Upon motion made within 90 days after the movant receives notice of the award pursuant to s. 682.09 or within 90 days after the movant receives notice of a modified or corrected award pursuant to s. 682.10, the court shall modify or correct the award if:

(a) There is an evident miscalculation of figures or an evident mistake in the description of any person, thing, or property referred to in the award.

(b) The arbitrators have awarded upon a matter not submitted in the arbitration and the award may be corrected without affecting the merits of the decision upon the issues submitted.

(2) If the motion is granted, the court shall modify and correct the award and confirm the award as so modified and corrected. Otherwise, unless a motion to vacate the award under s. 682.13 is pending, the court shall confirm the award as made.

(3) A motion to modify or correct an award may be joined in the alternative with a motion to vacate the award under s. 682.13.

History.—s. 13, ch. 57-402; s. 12, ch. 67-254; s. 730, ch. 97-102; s. 25, ch. 2013-232.

Note.—Former s. 57.23.

Notes of Decisions

Cited in 40 cases (2 in the last 5 years), 1969–2026 · leading case: Wells v. Halmac Dev., Inc., 189 So. 3d 1015 (Fla. 3d DCA 2016).

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Wells v. Halmac Dev., Inc., 189 So. 3d 1015 (Fla. 3d DCA 2016). · cites it 4× “See § 682.14(1), Fla. Stat. See also Cassara v.”

McDaniel v. Berhalter, 405 So. 2d 1027 (Fla. 4th DCA 1981). · cites it 5× “Such a construction would require us to ignore either the facts of this case or the language of Section 682.14. First, the record reveals no indication that the parties or the trial court considered that McDaniel was seeking a modification of the arbitrator's award pursuant to…”

Wells v. Castro, 117 So. 3d 1233 (Fla. 3d DCA 2013). · cites it 6× “” Wells responded to Castro’s motion arguing that Castro was attempting to have the merits re-determined, and that “[a] modification is limited to the scope of AAA R-48 or Fla. Stat. § 682.14 (l)(a), and the Arbitrator has determined, in accordance with Florida law, that there…”

Moser v. Barron Chase Sec., Inc., 783 So. 2d 231 (Fla. 2001). · cites it 2× “" Section 682.14(1)(c) provides for the modification or correction of an award where "[t]he award is imperfect as a matter of form, not affecting the merits of the controversy.”

Marr v. Webb, 930 So. 2d 734 (Fla. 3d DCA 2006). · cites it 4× “§ 682.14, Fla. Stat. (2005) (emphasis added).”

B & H Const. & Supply Co., Inc. v. Dist. Bd. of Trustess, Tallahassee Com. Coll. of Fla., 542 So. 2d 382 (Fla. 1st DCA 1989). · cites it 2× “However, we conclude that the trial court erred in excluding recovery of attorney's fees expended for services rendered after the date of the arbitration award.”

Nationbanc Sec., Inc. v. Aron, 787 So. 2d 881 (Fla. 2d DCA 2001). · cites it 5× “13 or section 682.14, and the relevant section is silent as to a time period requirement within which to confirm an award, the general, catch-all four-year statute of limitation period is, therefore, the operable period by which their request must be measured.”

Lumbermens Mut. Cas. Co. v. Martin, 399 So. 2d 536 (Fla. 3d DCA 1981). · cites it 2× “4th DCA 1966); Section 682.14(1)(c), Florida Statutes (1979); (b) In view of the clear and unrebutted testimony that a simple mistake had been made, the policy was properly reformed to change the named insured from Felix Martin to Francisco Martin, Sr.”

Midwest Mut. Ins. Co. v. Santiesteban, 287 So. 2d 665 (Fla. 1973). · cites it 2× “The basis for my dissent is that to escape liability under the claim of respondent, the petitioner should have refused arbitration, and filed a complaint in the trial court.”

Martin Daytona v. Strickland Const. Serv., 941 So. 2d 1220 (Fla. 5th DCA 2006). · cites it 2× “We also think it noteworthy that Strickland filed a post-hearing motion arguing that it should be deemed the prevailing party and submitted a proposed order to the arbitrator declaring it to be the prevailing party. Moreover, Strickland did not move to vacate the award pursuant…”

Lumbermens Mut. Ins. Co. v. Am. Arbitration Ass'n, 398 So. 2d 469 (Fla. 4th DCA 1981). · cites it 2× “On the contrary, Lumbermens merely availed itself of the procedures set forth in Section 682.14, Florida Statutes (1979), in order to avoid liability for that portion of the arbitration award (,000), which exceeded the ,000 policy limit.”

Citizens Prop. Ins. Corp. v. Cuban-Hebrew Congregation of Miami, Inc., 5 So. 3d 709 (Fla. 3d DCA 2009). · cites it 2× “The court concluded that Citizens had delayed unreasonably in bringing the issue to the court.”

Show all 40 citing cases →

— 682.14(1) — 6 cases

Wells v. Halmac Dev., Inc., 189 So. 3d 1015 (Fla. 3d DCA 2016). “See § 682.14(1), Fla. Stat. See also Cassara v.”

Fridman v. Citicorp Real Est., Inc., 596 So. 2d 1128 (Fla. 2d DCA 1992).

State Farm Florida Ins. v. Gonzalez, 76 So. 3d 34 (Fla. 3d DCA 2011).

Nestor v. Ward, 163 So. 3d 582 (Fla. 3d DCA 2015).

Bartke's, Inc. v. Hillsborough Cnty. Aviation Auth., 217 So. 2d 885 (Fla. 2d DCA 1969).

— 682.14(1)(a) — 6 cases

B & H Const. & Supply Co., Inc. v. Dist. Bd. of Trustess, Tallahassee Com. Coll. of Fla., 542 So. 2d 382 (Fla. 1st DCA 1989). “However, we conclude that the trial court erred in excluding recovery of attorney's fees expended for services rendered after the date of the arbitration award.”

McDaniel v. Berhalter, 405 So. 2d 1027 (Fla. 4th DCA 1981). “Such a construction would require us to ignore either the facts of this case or the language of Section 682.14. First, the record reveals no indication that the parties or the trial court considered that McDaniel was seeking a modification of the arbitrator's award pursuant to…”

Am. Serv. Mut. Ins. Co. v. Wilson, 323 So. 2d 645 (Fla. 3d DCA 1975).

Applewhite v. Sheen Fin. Resources, 608 So. 2d 80 (Fla. 4th DCA 1992).

Lopez & Roque Tile Co. Inc. v. Clearwater Dev. Corp., 291 So. 2d 126 (Fla. 2d DCA 1974).

— 682.14(1)(c) — 3 cases

Moser v. Barron Chase Sec., Inc., 783 So. 2d 231 (Fla. 2001). “" Section 682.14(1)(c) provides for the modification or correction of an award where "[t]he award is imperfect as a matter of form, not affecting the merits of the controversy.”

Lumbermens Mut. Cas. Co. v. Martin, 399 So. 2d 536 (Fla. 3d DCA 1981). “4th DCA 1966); Section 682.14(1)(c), Florida Statutes (1979); (b) In view of the clear and unrebutted testimony that a simple mistake had been made, the policy was properly reformed to change the named insured from Felix Martin to Francisco Martin, Sr.”

Oregon Partners No. 2, Ltd. v. Klauder & Nunno Enter., Inc., 837 So. 2d 1104 (Fla. 4th DCA 2003).

— 682.14(2) — 1 case

Florida Capital Grp., Inc. v. Bishop, 240 So. 3d 108 (Fla. 3d DCA 2018).

— 682.14(a) — 1 case

Greco v. Carlton, 793 So. 2d 1088 (Fla. 4th DCA 2001).

— 682.14(b) — 1 case

Robert W. Baird & Co. v. Sunamerica Sec., Inc., 399 F. Supp. 2d 1314 (M.D. Fla. 2005).

— 682.14(l)(a) — 1 case

Wells v. Halmac Dev., Inc., 189 So. 3d 1015 (Fla. 3d DCA 2016). “See § 682.14(1), Fla. Stat. See also Cassara v.”

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