ROY JAMES EDWARDS, APPELLANT,
v.
JULIE L. JONES, SECRETARY, FLORIDA DEPARTMENT OF CORRECTIONS, APPELLEE
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Roy Edwards appealed the dismissal of his civil complaint against the Florida Department of Corrections for loss of personal property. The circuit court lacked subject matter jurisdiction because the damages claimed ($22.48 plus $17.50) fell below the $15,000 threshold for circuit court jurisdiction, requiring reversal and remand to county court rather than dismissal.
The circuit court lacked subject matter jurisdiction because the damages alleged were below the $15,000 threshold for circuit court jurisdiction. A case must be transferred to county court rather than dismissed when the claimed damages fall within county court jurisdiction.
[1] A circuit court lacks subject matter jurisdiction over civil actions seeking damages below the statutory threshold for circuit court jurisdiction.
[2] A judgment rendered by a court lacking subject matter jurisdiction is void.
Previewing 2 of 5 headnotes on this case. FLexlaw’s editorially structured points of law — every proposition, pinpointed — are reserved for members.
Join FLexlaw to unlock all legal intelligence“a lack of subject matter jurisdiction renders a judgment void, 'and a void judgment can be attacked at any time, even collaterally.'”
Establishes that the circuit court's jurisdictional deficiency cannot be overlooked and requires reversal regardless of other issues.
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Join FLexlaw to unlock all legal intelligenceEdwards, an inmate at Columbia Correctional Institution, filed suit seeking damages for personal property allegedly taken by DOC employees. His compla…
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Appellant challenges the order dismissing with prejudice his complaint for monetary damages against the Florida Department of Corrections (DOC) as compensation for the loss of his personal property while housed at Columbia Correctional Institution. The dismissal - was based on Appellant’s failure to exhaust administrative remedies.
Appellant brought his suit in the circuit court, but alleged in the first paragraph of his complaint that, “This is an action for damages for a sum within the jurisdictional limits of this court, to wit: $15,000.00, pursuant to Article V § 6, § 20(c)(4), Florida Constitution ánd § 34.01, Florida Statutes (2014).” Later in his complaint, Appellant sought damages in the amount of $22:48 to replace his property allegedly taken by DOC employees and $17.50 for “Paper, Copies, and U.S. Postage.”
Without question, the specific amount of damages alleged is far below the jurisdictional threshold for the circuit court, pursuant to sections 26.012(2)(a) and 34.01(1)(c), Florida Statutes. The complaint quotes Article V, sections 6 and 20(c)(4) of the Florida Constitution, as well as section 34.01, Florida Statutes, all of which refer to county courts or their jurisdiction. Even if the first paragraph of the complaint is read to mean - Appellant was seeking $15,000 in damages (as opposed to seeking a sum within the purported $15,000 jurisdictional limit • of the circuit court), the amount sought is within the jurisdiction of the county court since circuit courts have jurisdiction only for those- civil matters which exceed $15,000 in damages. The circuit court lacked subject matter jurisdiction to hear this case. This jurisdictional deficiency requires reversal of the circuit court’s order and remand for the entry of an order transferring the case to the county court. Spradley v. Doe, 612 So.2d 722 *772(Fla. 1st DCA 1993); see also Hartley v. Tifft, 87 So.3d 54 (Fla. 1st DCA 2012).1
Appellee requests that we find that the end result would be the same under a harmless error analysis citing Special v. West Boca Medical Center, 160 So.3d 1251 (Fla. 2014). However, “a lack of subject matter jurisdiction renders a judgment void, ‘and a void judgment can be attacked at any time, even collaterally.’ ” Hardman v. Koslowski, 135 So.3d 434, 436 (Fla. 1st DCA 2014) (quoting Strommen v. Strommen, 927 So.2d 176, 179 (Fla. 2d DCA 2006)). The circuit court’s dismissal of the complaint for failure to exhaust administrative remedies was void for lack of subject matter jurisdiction. Whether Appellant exhausted his administrative remedies and any other matters which must be determined are properly within the jurisdiction of the county court.
REVERSED and REMANDED with directions.
WOLF and RAY, JJ., CONCUR.
Cases With Similar Vibessemantic neighbors from the corpus
Citator
Cited By
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Bejarano v. City of Hollywood, 279 So. 3d 183 (Fla. 4th DCA 2019)…issal in the event that alleged damages are below the jurisdictional amount for the circuit court is a transfer of that action to the county court. Aysisayh v. Ellis, 497 So. 2d 1316, 1317 (Fla. 1st DCA 1986); see also, e.g., Edwards v. Jones, 221 So. 3d 770, 772 n.1 (Fla. 1st DCA 2017); Martell v. Kurlan, 626 So. 2d 705, 705 (Fla. 4th DCA 1993) (stating that - 4 - “the amount in controversy as to each of those causes of action was below the jurisdictional limit; consequently, the action should h…
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Carter v. Vidal (Fla. 3d DCA 2020)…enue. We conclude that the circuit court was without subject matter jurisdiction to adjudicate these claims. We therefore reverse and remand with instructions to transfer the complaint to the county court for Miami-Dade County. See Edwards v. Jones, 221 So. 3d 770 (Fla. 1st DCA 2017). Reversed and remanded with instructions.…
Authorities Cited
- Special v. W. Boca Med. Ctr., 160 So. 3d 1251 (Fla. 2014)
- Strommen v. Strommen, 927 So. 2d 176 (Fla. 2d DCA 2006)
- Spradley v. DOE, 612 So. 2d 722 (Fla. 1st DCA 1993)
- Waadew Aysisayh v. C.W. Ellis, 497 So. 2d 1316 (Fla. 1st DCA 1986)
- Hardman v. Koslowski, 135 So. 3d 434 (Fla. 1st DCA 2014)
- Drew C. Hartley v. Tifft, 87 So. 3d 54 (Fla. 1st DCA 2012)
- Bowers v. Teresa A. Parrish (Hightower), 845 So. 2d 251 (Fla. 1st DCA 2003)