Federated National Insurance Company v. Restoration 1 of South Florida, LLC a/a/o Marie Loiseau

Summary

The Florida Fourth District Court of Appeal granted Federated National Insurance Company's petition for a writ of prohibition. It held that the circuit court lacked subject matter jurisdiction over the declaratory judgment action because the $1,196.66 amount in controversy did not exceed the $15,000 jurisdictional threshold, and directed transfer of the case to county court.

Holdings

1. A Florida circuit court lacks subject matter jurisdiction over a declaratory judgment action when the amount in controversy does not exceed $15,000; such an action falls within the jurisdiction of the county court.
2. When the circuit court lacks jurisdiction because the amount in controversy is below the circuit court's jurisdictional amount, the case should be transferred to county court.

Questions Presented

1. Whether the circuit court had subject matter jurisdiction over a declaratory judgment action involving $1,196.66.
2. Whether the appropriate remedy was to prohibit the circuit court from proceeding and transfer the action to county court.

Disposition

writ_granted