FEDAN CORPORATION A/K/A FEDAN TIRE AND HENRY ECHEVERRIA, APPELLANTS,
v.
MILVA REINA, APPELLEE
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Fedan Corporation and Henry Echeverria appealed a trial court order denying their motion to vacate a $250,000 judgment entered against them in a damages suit. The appellate court reversed, holding that the trial court lacked subject matter jurisdiction because the plaintiff's complaint alleged damages of only $10,000.01, which fell below the circuit court's jurisdictional threshold of $15,000.
The court held that the judgment was void because the circuit court lacked subject matter jurisdiction. The test for jurisdiction based on amount in controversy is the amount in good faith claimed when the action is commenced; here, Reina claimed only $10,000.01, below the $15,000 jurisdictional requirement. A judgment entered where a court lacks subject matter jurisdiction is a nullity regardless of the final judgment amount.
[1] A circuit court lacks subject matter jurisdiction over an action at law when the amount in controversy, as alleged in good faith at the commencement of the action, does n…
[2] A judgment entered by a court that lacks subject matter jurisdiction is void and a nullity, regardless of whether the final judgment amount falls within the court's juris…
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Join FLexlaw to unlock all legal intelligence“The test to determine the jurisdiction of the court is the amount in good faith claimed or put in controversy when the action is commenced.”
Establishes the standard for determining whether a court has subject matter jurisdiction based on amount in controversy—it is measured at the time of filing, not the ultimate judgment.
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Join FLexlaw to unlock all legal intelligenceMilva Reina filed suit against Fedan Corporation and Henry Echeverria in November 1994, alleging damages exceeding $10,000. The trial court entered a …
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NESBITT, Judge.
Defendants-appellants appeal a non-final order denying their motion to vacate a judgment. We reverse.
Milva Reina filed suit against the defendants in the circuit court in November 1994. Reina’s complaint alleged in pertinent part: “This is an action for damages that exceed $10,000.00 as to the plaintiff.” Ultimately, the trial court entered a default on liability against the defendants. After a jury trial on damages at which the defendants did not appear, the trial court, on December 17, 1996, entered a judgment in Reina’s favor for $250,000. On April 18, 1997, the defendants filed a motion for relief from the judgment. They argued that the judgment was void as the court lacked subject matter jurisdiction over a complaint that alleged an amount in controversy insufficient to confer jurisdiction on the circuit court. The trial court denied the motion, and this appeal followed.
As of July 1, 1992, the circuit courts have jurisdiction of all actions at law where the matter in controversy exceeds the sum of $15,000, exclusive of interest, costs, and attorney’s fees. See §§ 26.012(2)(a), 34.01(c)4, Fla. Stat. (1995). Where the court’s jurisdiction is based on the amount in controversy, “[t]he test to determine the jurisdiction of the court is the amount in good faith claimed or put in controversy when the action is commenced.” Soler v. Independent Fire Ins. Co., 625 So. 2d 905, 906 (Fla. 3d DCA 1993)(internal quotations and citations omitted). When Reina commenced this action, she claimed that her damages exceeded llOjOOO.1 The circuit court has jurisdiction where the minimum amount claimed, exclusive of interest, costs, and attorney’s fees, is greater than the maximum amount of the county court’s jurisdiction. See Caudell v. Leventis, 43 So. 2d 853, 854 (Fla.1950). Given her allegation, the minimum amount of damages claimed by Reina was $10,000.01. That amount was clearly not within the circuit court’s subject matter jurisdiction. Thus, the judgment rendered by the court is void. See Malone v. Meres, 91 Fla. 709, 724, 109 So. 677, 683 (1926). The fact that the circuit court ultimately entered a judgment for an amount that was within its jurisdiction is irrelevant, as a judgment entered where the court lacks subject matter jurisdiction is a nullity. Id.
,
Consequently, we reverse the order denying the defendants’ motion to vacate the judgment and remand with directions to vacate the subject judgment.
. No amendment was ever made to the complaint, and no amended complaint was ever Bled.
. In Champion v. Rakes, 155 Ga.App. 134, 270 S.E. 2d 272 (1980), a Georgia appellate court was "confronted with a question of whether a court which had no jurisdiction of the subject matter when suit was filed can obtain jurisdiction by rendering a judgment which is within such court’s jurisdiction." In a persuasive analysis of the problem, the court answered the question in the negative.
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Ilana Ben-David v. The Educ. Res. Inst., Inc., 974 So. 2d 1138 (Fla. 3d DCA 2008)…gment is void and we need not address the other issues raised by Ben-David. See Strommen v. Strommen, 927 So. 2d 176, 179 (Fla. 2d DCA 2006) (“A trial court’s lack of subject matter jurisdiction makes its judgments void.... ”); Fedan Corp. v. Reina, 695 So. 2d 1282, 1283 (Fla. 3d DCA 1997) (judgment rendered by court is void if court lacks subject matter jurisdiction). “Subject matter jurisdiction — the ‘power of the trial court to deal with a class of cases to which a particular case belongs’ — is conferred…
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Haire v. Overseas Holdings Ltd. P'ship, 908 So. 2d 580 (Fla. 2d DCA 2005)…urisdiction over Mr. Haire’s damage claims. The crux of Mr. Haire’s lawsuit was that OHLP defrauded him. His claims for [*583] damages against OHLP were within the trial courts jurisdiction. See 26.012(2)(a), Fla. Stat. (2000); Fedan Corp. v. Reina, 695 So. 2d 1282, 1283 (Fla. 3d DCA 1997). Moreover, Mr. Haire’s damage claims did not interfere with the receivers exclusive possession of and control over the note. Indeed, “the appointment of the receiver does not necessarily draw to the federal court the exclusi…
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Lazow v. Amber B. Glasper, P.A. (Fla. 3d DCA 2024)…was at issue. “Where the court's jurisdiction is based on the amount in controversy, the test to determine the jurisdiction of the court is the amount in good faith claimed or put in controversy when the action is commenced.” Fedan Corp. v. Reina, 695 So. 2d 1282, 1282 (Fla. 3d DCA 1997) (emphasis added) (internal quotations and citation omitted); see Plutt v. Ross, 230 So. 3d 883, 885 (Fla. 4th DCA 2017) (“[J]urisdiction is properly invoked by filing the complaint . . . .”); see also Metro. Drywall Sys., In…
Previewing 3 of 4 citing cases — full citator treatment, depth of discussion, and citing context are member features.
Join FLexlaw to unlock all legal intelligenceAuthorities Cited
- Malone v. Meres, 109 So. 677 (Fla. 1926)
- Caudell v. Leventis, 43 So.2d 853 (Fla. 1950)
- Luis F. Soler and Maria v. Soler, 625 So. 2d 905 (Fla. 3d DCA 1993)