Florida Statutes

Fla. Stat. § 731.201 (2025)

General definitions.

✓ 2025 Florida Statutes — current through the 2025 Regular Session

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731.201 General definitions.—Subject to additional definitions in subsequent chapters that are applicable to specific chapters or parts, and unless the context otherwise requires, in this code, in s. 409.9101, and in chapters 736, 738, 739, and 744, the term:

(1) “Authenticated,” when referring to copies of documents or judicial proceedings required to be filed with the court under this code, means a certified copy or a copy authenticated according to the Federal Rules of Civil Procedure.

(2) “Beneficiary” means heir at law in an intestate estate and devisee in a testate estate. The term “beneficiary” does not apply to an heir at law or a devisee after that person’s interest in the estate has been satisfied. In the case of a devise to an existing trust or trustee, or to a trust or trustee described by will, the trustee is a beneficiary of the estate. Except as otherwise provided in this subsection, the beneficiary of the trust is not a beneficiary of the estate of which that trust or the trustee of that trust is a beneficiary. However, if each trustee is also a personal representative of the estate, each qualified beneficiary of the trust as defined in s. 736.0103 shall be regarded as a beneficiary of the estate.

(3) “Child” includes a person entitled to take as a child under this code by intestate succession from the parent whose relationship is involved, and excludes any person who is only a stepchild, a foster child, a grandchild, or a more remote descendant.

(4) “Claim” means a liability of the decedent, whether arising in contract, tort, or otherwise, and funeral expense. The term does not include an expense of administration or estate, inheritance, succession, or other death taxes.

(5) “Clerk” means the clerk or deputy clerk of the court.

(6) “Collateral heir” means an heir who is related to the decedent through a common ancestor but who is not an ancestor or descendant of the decedent.

(7) “Court” means the circuit court.

(8) “Curator” means a person appointed by the court to take charge of the estate of a decedent until letters are issued.

(9) “Descendant” means a person in any generational level down the applicable individual’s descending line and includes children, grandchildren, and more remote descendants. The term “descendant” is synonymous with the terms “lineal descendant” and “issue” but excludes collateral heirs.

(10) “Devise,” when used as a noun, means a testamentary disposition of real or personal property and, when used as a verb, means to dispose of real or personal property by will or trust. The term includes “gift,” “give,” “bequeath,” “bequest,” and “legacy.” A devise is subject to charges for debts, expenses, and taxes as provided in this code, the will, or the trust.

(11) “Devisee” means a person designated in a will or trust to receive a devise. Except as otherwise provided in this subsection, in the case of a devise to an existing trust or trustee, or to a trust or trustee of a trust described by will, the trust or trustee, rather than the beneficiaries of the trust, is the devisee. However, if each trustee is also a personal representative of the estate, each qualified beneficiary of the trust as defined in s. 736.0103 shall be regarded as a devisee.

(12) “Distributee” means a person who has received estate property from a personal representative or other fiduciary other than as a creditor or purchaser. A testamentary trustee is a distributee only to the extent of distributed assets or increments to them remaining in the trustee’s hands. A beneficiary of a testamentary trust to whom the trustee has distributed property received from a personal representative is a distributee. For purposes of this provision, “testamentary trustee” includes a trustee to whom assets are transferred by will, to the extent of the devised assets.

(13) “Domicile” means a person’s usual place of dwelling and shall be synonymous with residence.

(14) “Estate” means the property of a decedent that is the subject of administration.

(15) “Exempt property” means the property of a decedent’s estate which is described in s. 732.402.

(16) “File” means to file with the court or clerk.

(17) “Foreign personal representative” means a personal representative of another state or a foreign country.

(18) “Formal notice” means a form of notice that is described in and served by a method of service provided under rule 5.040(a) of the Florida Probate Rules.

(19) “Grantor” means one who creates or adds to a trust and includes “settlor” or “trustor” and a testator who creates or adds to a trust.

(20) “Heirs” or “heirs at law” means those persons, including the surviving spouse, who are entitled under the statutes of intestate succession to the property of a decedent.

(21) “Incapacitated” means a judicial determination that a person lacks the capacity to manage at least some of the person’s property or to meet at least some of the person’s essential health and safety requirements. A minor shall be treated as being incapacitated.

(22) “Informal notice” or “notice” means a method of service for pleadings or papers as provided under rule 5.040(b) of the Florida Probate Rules.

(23) “Interested person” means any person who may reasonably be expected to be affected by the outcome of the particular proceeding involved. In any proceeding affecting the estate or the rights of a beneficiary in the estate, the personal representative of the estate shall be deemed to be an interested person. In any proceeding affecting the expenses of the administration and obligations of a decedent’s estate, or any claims described in s. 733.702(1), the trustee of a trust described in s. 733.707(3) is an interested person in the administration of the grantor’s estate. The term does not include a beneficiary who has received complete distribution. The meaning, as it relates to particular persons, may vary from time to time and must be determined according to the particular purpose of, and matter involved in, any proceedings.

(24) “Letters” means authority granted by the court to the personal representative to act on behalf of the estate of the decedent and refers to what has been known as letters testamentary and letters of administration. All letters shall be designated “letters of administration.”

(25) “Minor” means a person under 18 years of age whose disabilities have not been removed by marriage or otherwise.

(26) “Other state” means any state of the United States other than Florida and includes the District of Columbia, the Commonwealth of Puerto Rico, and any territory or possession subject to the legislative authority of the United States.

(27) “Parent” excludes any person who is only a stepparent, foster parent, or grandparent.

(28) “Personal representative” means the fiduciary appointed by the court to administer the estate and refers to what has been known as an administrator, administrator cum testamento annexo, administrator de bonis non, ancillary administrator, ancillary executor, or executor.

(29) “Petition” means a written request to the court for an order.

(30) “Power of appointment” means an authority, other than as an incident of the beneficial ownership of property, to designate recipients of beneficial interests in property.

(31) “Probate of will” means all steps necessary to establish the validity of a will and to admit a will to probate.

(32) “Property” means both real and personal property or any interest in it and anything that may be the subject of ownership, including causes of action of the estate and causes of action the decedent had at the time of death.

(33) “Protected homestead” means the property described in s. 4(a)(1), Art. X of the State Constitution on which at the death of the owner the exemption inures to the owner’s surviving spouse or heirs under s. 4(b), Art. X of the State Constitution. For purposes of the code, real property owned in tenancy by the entireties or in joint tenancy with rights of survivorship is not protected homestead.

(34) “Residence” means a person’s place of dwelling.

(35) “Residuary devise” means a devise of the assets of the estate which remain after the provision for any devise which is to be satisfied by reference to a specific property or type of property, fund, sum, or statutory amount. If the will contains no devise which is to be satisfied by reference to a specific property or type of property, fund, sum, or statutory amount, “residuary devise” or “residue” means a devise of all assets remaining after satisfying the obligations of the estate.

(36) “Security” means a security as defined in s. 517.021.

(37) “Security interest” means a security interest as defined in s. 671.201.

(38) “Trust” means an express trust, private or charitable, with additions to it, wherever and however created. It also includes a trust created or determined by a judgment or decree under which the trust is to be administered in the manner of an express trust. “Trust” excludes other constructive trusts, and it excludes resulting trusts; conservatorships; custodial arrangements pursuant to the Florida Uniform Transfers to Minors Act; business trusts providing for certificates to be issued to beneficiaries; common trust funds; land trusts under s. 689.071, except to the extent provided in s. 689.071(7); trusts created by the form of the account or by the deposit agreement at a financial institution; voting trusts; security arrangements; liquidation trusts; trusts for the primary purpose of paying debts, dividends, interest, salaries, wages, profits, pensions, or employee benefits of any kind; and any arrangement under which a person is nominee or escrowee for another.

(39) “Trustee” includes an original, additional, surviving, or successor trustee, whether or not appointed or confirmed by court.

(40) “Will” means a testamentary instrument, including a codicil, executed by a person in the manner prescribed by this code, which disposes of the person’s property on or after his or her death and includes an instrument which merely appoints a personal representative or guardian or revokes or revises another will. The term includes an electronic will as defined in s. 732.521.

History.—s. 1, ch. 74-106; s. 4, ch. 75-220; s. 1, ch. 77-174; s. 2, ch. 85-79; s. 66, ch. 87-226; s. 1, ch. 88-340; s. 7, ch. 93-257; s. 6, ch. 95-401; s. 949, ch. 97-102; s. 52, ch. 98-421; s. 11, ch. 2001-226; s. 106, ch. 2002-1; s. 2, ch. 2003-154; s. 2, ch. 2005-108; s. 29, ch. 2006-217; s. 3, ch. 2007-74; s. 8, ch. 2007-153; s. 1, ch. 2009-115; s. 4, ch. 2010-132; s. 1, ch. 2012-109; s. 16, ch. 2013-172; s. 30, ch. 2019-71; s. 2, ch. 2020-67.

Note.—Created from former s. 731.03.

Notes of Decisions

Cited in 203 cases (27 in the last 5 years), 1977–2026 · leading case: Snyder v. Davis, 699 So. 2d 999 (Fla. 1997).

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Snyder v. Davis, 699 So. 2d 999 (Fla. 1997). · cites it 18× “Section 731.201(18), Florida Statutes (1989), defines heirs or heirs at law as "those persons.”

Amendments to the Florida Prob. Rules, 848 So. 2d 1069 (Fla. 2003). · cites it 32× “§ 731.201, Fla. Stat. General definitions.”

Hayes v. Guardianship of Thompson, 952 So. 2d 498 (Fla. 2006). · cites it 5× “§ 731.201(21), Fla. Stat. (2006). Thus, unlike a ward, a guardian, or next of kin, who are specific persons occupying finite, statutorily defined roles, [12] the definition of "interested person" requires the trial court to evaluate the nature of both the proceeding and the…”

Wheeler v. Powers, 972 So. 2d 285 (Fla. 5th DCA 2008). · cites it 7× “. . . The meaning, as it relates to particular persons, may vary from time to time and must be determined according to the particular purpose of, and matter involved in, any proceedings.”

In Re Amendments to the Fl. Prob. Rules, 964 So. 2d 140 (Fla. 2007). · cites it 25× “§ 731.201, Fla. Stat. General definitions.”

Berges v. Infinity Ins. Co., 896 So. 2d 665 (Fla. 2004). · cites it 2× “3d DCA 1995) ("The personal representative is the individual having the power to enter into settlements of wrongful death actions"); § 731.201, Fla. Stat. (1989) (defining letters of administration as the "authority granted by the court to the personal representative to act on…”

McKean v. Warburton, 919 So. 2d 341 (Fla. 2006). · cites it 4× “[1] Although section 731.201, Florida Statutes (2004), does not define homestead, it defines "protected homestead" as that property described in the Florida Constitution "on which at the death of the owner the exemption inures to the owner's surviving spouse or heirs.”

Hernandez Sr. v. Hernandez, 230 So. 3d 119 (Fla. 3d DCA 2017). · cites it 18× “at 507 (citing § 731.201(21), Fla. Stat. (2006)).2 Thus, “the definition of ‘interested person’ requires the trial court to evaluate the nature of both the proceeding and the interest asserted.”

Florida Bar, 537 So. 2d 500 (Fla. 1988). · cites it 8× “540 and also F.S. 731.201 and F.S. 744.102. 1988 Revision: Rule was expanded due to deletion of FPR 5.”

Cutler v. Cutler, 994 So. 2d 341 (Fla. 3d DCA 2008). · cites it 4× “X of the State Constitution on which at the death of the owner the exemption inures to the owner's surviving spouse or heirs under s. 4(b), Art. X of the State Constitution"); § 733.”

Robert Blechman & Cathy Blechman Chermak v. Est. of Bertram Blechman, 160 So. 3d 152 (Fla. 4th DCA 2015). · cites it 4× “” § 731.201(14), Fla. Stat. (2011). In deciphering a probate estate’s parameters, the deciding factor is the decedent’s ownership interest in property.”

Amendments to the Florida Rules of Civil Procedure, 858 So. 2d 1013 (Fla. 2003). · cites it 4× “” See § 731.201(25), Fla. Stat. (2002). Rule 1.”

Show all 203 citing cases →

— 731.201(1) — 2 cases

Lewin v. Marksbury, 374 So. 2d 58 (Fla. 3d DCA 1979).

In re Amendments to the Florida Prob. Rules, 912 So. 2d 1178 (Fla. 2005).

— 731.201(10) — 13 cases

In Re Est. of Johnson, 347 So. 2d 785 (Fla. 1st DCA 1977).

In Re Ciano, 433 B.R. 431 (Bankr. N.D. Fla. 2010).

Amendments to the Florida Prob. Rules, 848 So. 2d 1069 (Fla. 2003). “§ 731.201, Fla. Stat. General definitions.”

In Re Est. of Johnson, 359 So. 2d 425 (Fla. 1978).

In Re Amendments to the Fl. Prob. Rules, 964 So. 2d 140 (Fla. 2007). “§ 731.201, Fla. Stat. General definitions.”

— 731.201(11) — 1 case

Cuevas v. Kelly, 873 So. 2d 367 (Fla. 2d DCA 2004).

— 731.201(12) — 2 cases

Paredes v. McLucas, 561 So. 2d 439 (Fla. 2d DCA 1990).

Grant v. Norris, 558 So. 2d 208 (Fla. 2d DCA 1990).

— 731.201(13) — 4 cases

Paredes v. McLucas, 561 So. 2d 439 (Fla. 2d DCA 1990).

Colin Markes & Sharon Hart- Corrigan v. Est. of Keith Albert Markes (Fla. 4th DCA 2025).

Luiza Mara Reis Dos Santos Fernandes De Oliveira v. Natalia Palagi Fernandes De Oliveira (Fla. 3d DCA 2026).

Grant v. Norris, 558 So. 2d 208 (Fla. 2d DCA 1990).

— 731.201(14) — 4 cases

Samuel M. Depriest & Dorothy Depriest v. Richard Greeson, as Pers. etc., 213 So. 3d 1022 (Fla. 1st DCA 2017).

Robert Blechman & Cathy Blechman Chermak v. Est. of Bertram Blechman, 160 So. 3d 152 (Fla. 4th DCA 2015). “” § 731.201(14), Fla. Stat. (2011). In deciphering a probate estate’s parameters, the deciding factor is the decedent’s ownership interest in property.”

De Fernandez v. Seaboard Marine Ltd (S.D. Fla. 2021).

Robert Blechman & Cathy Blechman Chermak v. Est. of Bertram Blechman (Fla. 4th DCA 2015).

— 731.201(16) — 11 cases

Florida Bar, 537 So. 2d 500 (Fla. 1988). “540 and also F.S. 731.201 and F.S. 744.102. 1988 Revision: Rule was expanded due to deletion of FPR 5.”

In Re Amendments to the Florida Prob. Rules, 584 So. 2d 964 (Fla. 1991).

Amendments to the Florida Prob. Rules, 848 So. 2d 1069 (Fla. 2003). “§ 731.201, Fla. Stat. General definitions.”

Florida Bar re Amendment to Rules, 458 So. 2d 1079 (Fla. 1984).

In Re Amendments to the Fl. Prob. Rules, 964 So. 2d 140 (Fla. 2007). “§ 731.201, Fla. Stat. General definitions.”

— 731.201(17) — 1 case

Juega v. Davidson, 105 So. 3d 575 (Fla. 3d DCA 2012).

— 731.201(18) — 22 cases

Snyder v. Davis, 699 So. 2d 999 (Fla. 1997). “Section 731.201(18), Florida Statutes (1989), defines heirs or heirs at law as "those persons.”

Pub. Health Tr. of Dade Cty. v. Lopez, 531 So. 2d 946 (Fla. 1988).

Walker v. Mickler, 687 So. 2d 1328 (Fla. 1st DCA 1997).

Bartelt v. Bartelt, 579 So. 2d 282 (Fla. 3d DCA 1991).

Davis v. Snyder, 681 So. 2d 1191 (Fla. 2d DCA 1996).

— 731.201(19) — 1 case

Cason Ex Rel. Saferight v. Hammock, 908 So. 2d 512 (Fla. 5th DCA 2005).

— 731.201(2) — 13 cases

In re Est. of Herman, 427 So. 2d 195 (Fla. 4th DCA 1982).

In Re Est. of Walters, 700 So. 2d 434 (Fla. 4th DCA 1997).

Smith v. Bank of Clearwater, 479 So. 2d 755 (Fla. 2d DCA 1985).

Amendments to the Florida Prob. Rules, 848 So. 2d 1069 (Fla. 2003). “§ 731.201, Fla. Stat. General definitions.”

In Re Amendments to the Fl. Prob. Rules, 964 So. 2d 140 (Fla. 2007). “§ 731.201, Fla. Stat. General definitions.”

— 731.201(21) — 47 cases

Hayes v. Guardianship of Thompson, 952 So. 2d 498 (Fla. 2006). “§ 731.201(21), Fla. Stat. (2006). Thus, unlike a ward, a guardian, or next of kin, who are specific persons occupying finite, statutorily defined roles, [12] the definition of "interested person" requires the trial court to evaluate the nature of both the proceeding and the…”

Wheeler v. Powers, 972 So. 2d 285 (Fla. 5th DCA 2008). “. . . The meaning, as it relates to particular persons, may vary from time to time and must be determined according to the particular purpose of, and matter involved in, any proceedings.”

Amendments to the Florida Prob. Rules, 848 So. 2d 1069 (Fla. 2003). “§ 731.201, Fla. Stat. General definitions.”

In Re Guardianship of Schiavo, 792 So. 2d 551 (Fla. 2d DCA 2001).

Wolf Sanitary Wiping Cloth, Inc. v. Wolf, 526 So. 2d 702 (Fla. 3d DCA 1988).

— 731.201(21)(23) — 1 case

In Re Amendments to the Fl. Prob. Rules, 964 So. 2d 140 (Fla. 2007). “§ 731.201, Fla. Stat. General definitions.”

— 731.201(23) — 38 cases

Hernandez Sr. v. Hernandez, 230 So. 3d 119 (Fla. 3d DCA 2017). “at 507 (citing § 731.201(21), Fla. Stat. (2006)).2 Thus, “the definition of ‘interested person’ requires the trial court to evaluate the nature of both the proceeding and the interest asserted.”

Est. of Arroyo v. Infinity Indem. Ins. Co., 211 So. 3d 240 (Fla. 3d DCA 2017).

Gordon v. Kleinman, 120 So. 3d 120 (Fla. 4th DCA 2013).

Kountze v. Kountze, 20 So. 3d 428 (Fla. 2d DCA 2009).

Bloom v. Bloom, 227 So. 3d 165 (Fla. 2d DCA 2017).

— 731.201(24) — 2 cases

Ori Avraham Gordin & Teresa Shelley v. Est. of Shelley Wilensky Shelley Maisel a/k/a Shelley W. Shelley & Daniel W. Shelley, 179 So. 3d 518 (Fla. 4th DCA 2015).

Naftel v. Pappas, 68 So. 3d 368 (Fla. 1st DCA 2011).

— 731.201(25) — 3 cases

Amendments to the Florida Rules of Civil Procedure, 858 So. 2d 1013 (Fla. 2003). “” See § 731.201(25), Fla. Stat. (2002). Rule 1.”

In Re Est. of Fresia, 390 So. 2d 176 (Fla. 5th DCA 1980).

Funchess v. Gulf Stream Apts., 611 So. 2d 43 (Fla. 4th DCA 1992).

— 731.201(28) — 3 cases

In Re Est. of Hatcher, 439 So. 2d 977 (Fla. 3d DCA 1983).

Grobard v. Grobard, 382 So. 2d 117 (Fla. 3d DCA 1980).

Juega v. Davidson, 105 So. 3d 575 (Fla. 3d DCA 2012).

— 731.201(29) — 9 cases

Amendments to the Florida Prob. Rules, 848 So. 2d 1069 (Fla. 2003). “§ 731.201, Fla. Stat. General definitions.”

McKean v. Warburton, 919 So. 2d 341 (Fla. 2006). “[1] Although section 731.201, Florida Statutes (2004), does not define homestead, it defines "protected homestead" as that property described in the Florida Constitution "on which at the death of the owner the exemption inures to the owner's surviving spouse or heirs.”

Cutler v. Cutler, 994 So. 2d 341 (Fla. 3d DCA 2008). “X of the State Constitution on which at the death of the owner the exemption inures to the owner's surviving spouse or heirs under s. 4(b), Art. X of the State Constitution"); § 733.”

In Re Amendments to the Fl. Prob. Rules, 964 So. 2d 140 (Fla. 2007). “§ 731.201, Fla. Stat. General definitions.”

Harrell v. Snyder, 913 So. 2d 749 (Fla. 5th DCA 2005).

— 731.201(29)(31) — 1 case

In Re Amendments to the Fl. Prob. Rules, 964 So. 2d 140 (Fla. 2007). “§ 731.201, Fla. Stat. General definitions.”

— 731.201(30) — 1 case

J. Scott Lanford, Tr. of the Kirk Fam. Found. Vs Robin Phemister, Pers. Rep. of the Est. of Mary L. Dillard & as Tr. of the Testamentary Trust of Mary L. Dillard (Fla. 5th DCA 2022).

— 731.201(31) — 1 case

Clarke v. Schimmel, 774 So. 2d 7 (Fla. 2d DCA 2000).

— 731.201(32) — 4 cases

Wilson v. Wilson, 138 So. 3d 1176 (Fla. 4th DCA 2014).

Robert Blechman & Cathy Blechman Chermak v. Est. of Bertram Blechman (Fla. 4th DCA 2015).

In re GAC Corp., 64 B.R. 345 (S.D. Fla. 1986).

— 731.201(33) — 5 cases

Brigham v. Brigham, 11 So. 3d 374 (Fla. 3d DCA 2009).

In Re: Amendments to the Florida Prob. Rules - 2021 Fast-Track Report (Fla. 2021).

In Re: Amendments to Florida Prob. Rules (Fla. 2024).

In Re: Amendments to Florida Prob. Rule 5.405 (Fla. 2025).

Warner v. Quicken Loans, Inc. (M.D. Fla. 2020).

— 731.201(34) — 2 cases

Colin Markes & Sharon Hart- Corrigan v. Est. of Keith Albert Markes (Fla. 4th DCA 2025).

Luiza Mara Reis Dos Santos Fernandes De Oliveira v. Natalia Palagi Fernandes De Oliveira (Fla. 3d DCA 2026).

— 731.201(3433) — 1 case

In Re Amendments to the Florida Prob. Rules, 50 So. 3d 578 (Fla. 2010).

— 731.201(35) — 6 cases

In Re Est. of Tolin, 622 So. 2d 988 (Fla. 1993).

In Re Est. of Corbin, 645 So. 2d 39 (Fla. 1st DCA 1994).

In Re Est. of McGahee, 550 So. 2d 83 (Fla. 1st DCA 1989).

Corbin v. Sherman, 645 So. 2d 39 (Fla. 1st DCA 1994).

Est. of Woodfin v. Adkins, 20 Fla. Supp. 2d 56 (Fla. Cir. Ct. 1986).

— 731.201(36) — 1 case

Glenn v. Roberts, 95 So. 3d 271 (Fla. 3d DCA 2012).

— 731.201(4) — 17 cases

Spohr v. Berryman, 589 So. 2d 225 (Fla. 1991).

Browning v. Browning, 784 So. 2d 1145 (Fla. 2d DCA 2001).

Foster v. Cianci, 773 So. 2d 1181 (Fla. 2d DCA 2000).

Johnson v. Girtman, 542 So. 2d 1033 (Fla. 3d DCA 1989).

In Re Est. of Kulow, 439 So. 2d 280 (Fla. 2d DCA 1983).

— 731.201(40) — 1 case

Smith v. DeParry, 86 So. 3d 1228 (Fla. 2d DCA 2012).

— 731.201(6) — 1 case

Mosley v. Thomas, 402 So. 2d 594 (Fla. 5th DCA 1981).

— 731.201(7) — 2 cases

Long v. Willis, 100 So. 3d 4 (Fla. 2d DCA 2011).

Juega v. Davidson, 105 So. 3d 575 (Fla. 3d DCA 2012).

— 731.201(8) — 7 cases

Grobard v. Grobard, 382 So. 2d 117 (Fla. 3d DCA 1980).

In Re Est. of Walters, 700 So. 2d 434 (Fla. 4th DCA 1997).

Walters v. Edwards, 700 So. 2d 434 (Fla. 4th DCA 1997).

Ori Avraham Gordin & Teresa Shelley v. Est. of Shelley Wilensky Shelley Maisel a/k/a Shelley W. Shelley & Daniel W. Shelley, 179 So. 3d 518 (Fla. 4th DCA 2015).

— 731.201(9) — 7 cases

In Re Est. of Rice, 406 So. 2d 469 (Fla. 3d DCA 1981).

Snyder v. Davis, 699 So. 2d 999 (Fla. 1997). “Section 731.201(18), Florida Statutes (1989), defines heirs or heirs at law as "those persons.”

Timmons v. Ingrahm, 36 So. 3d 861 (Fla. 5th DCA 2010).

In re Est. of Herman, 427 So. 2d 195 (Fla. 4th DCA 1982).

Bartelt v. Bartelt, 579 So. 2d 282 (Fla. 3d DCA 1991).

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.