Florida Statutes

Fla. Stat. § 713.37 (2025)

Rule of construction.

✓ 2025 Florida Statutes — current through the 2025 Regular Session
Find cases: SyfertCases citing this section FL-LEGleg.state.fl.us JustiaFla. Statutes CornellLII Search CasesGoogle Scholar
713.37 Rule of construction.This part shall not be subject to a rule of liberal construction in favor of any person to whom it applies.
History.s. 15, ch. 77-353.
Notes of Decisions
Cited in 12 cases, 1982–2010 · leading case: Trytek v. Gale Indus., Inc., 3 So. 3d 1194 (Fla. 2009).
Trytek v. Gale Indus., Inc., 3 So. 3d 1194 (Fla. 2009). · cites it 2× “Further, in 1977, the Legislature enacted section 713.37, which states that “[the Construction Lien Law] shall not be subject to a rule of liberal construction in favor of any person to whom it applies.”
Sprinkler Fitters v. FITR SERV., 461 So. 2d 144 (Fla. 3d DCA 1984). · cites it 4× “See § 713.37, Fla. Stat. (1981) ("This part [the Mechanics' Lien Law] shall not be subject to a rule of liberal construction in favor of any person to whom it applies.”
Julian E. Johnson & Sons, Inc. v. Balboa Ins. Co., 408 So. 2d 1044 (Fla. 1982). · cites it 2× “29 reads as follows: In any action brought to enforce a lien under part I of this chapter, the prevailing party shall be entitled to recover a reasonable fee for the services of his attorney, to be determined by the court, which shall be taxed as part of his costs. [3] Ch.…”
Saleh v. Watkins, 415 So. 2d 858 (Fla. 5th DCA 1982). · cites it 2× “The contractor shall execute the affidavit and deliver it to the owner at least 5 days before instituting an action as a prerequisite to the institution of any action to enforce his lien under this chapter, even if the final payment has not become due because the contract is…”
Zalay v. Ace Cabinets of Clearwater, Inc., 700 So. 2d 15 (Fla. 2d DCA 1997). · cites it 2× “Thus, the Zalays' argument could apply in virtually any lien action involving persons not in privity. Since 1977, the construction lien statutes have provided that they should not be liberally construed in favor of any person.”
CDC Builders, Inc. v. Riviera Almeria, LLC, 51 So. 3d 510 (Fla. 3d DCA 2010). “” Instead, the trial court relied on its interpretation that chapter 713, when read as a whole, “requires a contractor to comply with all provisions contained therein.”
New Image Carpets, Inc. v. SANDERY CONST., INC., 541 So. 2d 1235 (Fla. 2d DCA 1989). · cites it 2× “§ 713.37, Fla. Stat. (1987) ("This part shall not be subject to a rule of liberal construction.”
Bracco v. Cardozo, 434 So. 2d 1024 (Fla. 2d DCA 1983). · cites it 2× “1981), that the legislature, by enacting section 713.37, which became effective July 1, 1978, abrogated the rule of liberal construction enunciated in Crane Company v.”
Davis Water & Waste Indus., Inc. v. Embry Dev. Corp., 603 So. 2d 1357 (Fla. 1st DCA 1992). · cites it 2× “§ 713.37, Fla. Stat. (1989). The analysis employed by the special assessment cases is not applicable, since such assessments are statutorily allowed for specially benefitted property, and fairly expansive procedural requirements are imposed by statute in the case of special…”
Action Labor of Florida v. Liberty Mut., 879 So. 2d 1240 (Fla. 3d DCA 2004). · cites it 2× “01 to include "a temporary help firm as defined in *1242 § 443.”
Walter E. Heller & Co. Se. v. Palmer-Smith, 504 So. 2d 511 (Fla. 5th DCA 1987). “Section 713.37 provides that “[t]his part shall not be subject to a rule of liberal construction in favor of any person to whom it applies.”
Trytek v. Gale Indus., Inc., 997 So. 2d 365 (Fla. 2008). · cites it 2× “Further, in 1977, the Legislature enacted section 713.37, which states that "[the Construction Lien Law] shall not be subject to a rule of liberal construction in favor of any person to whom it applies.”
Annotations are extracted automatically from the opinions in the Syfert caselaw corpus and ranked by authority, recency, and treatment. Dots show Syfertize treatment of the citing case itself.

This Florida statute resource is curated by this site's author, a Jacksonville, Florida personal injury and workers' compensation attorney (Florida Bar No. 39104). For legal consultation, call 904-383-7448.