In re Estate of Charles W. Smith, Deceased. Dale S. Wilson, et al., Petitioners/Appellants, v. Shirley I. Scruggs, Respondent/Appellee.

Summary

The Florida Supreme Court held that the four-year statute of limitations for paternity actions, § 95.11(3)(b), Fla. Stat., applies to paternity adjudications brought in probate under § 732.108(2)(b) for intestate succession, because the statute’s plain language covers all actions relating to paternity and no probate exemption exists. The court also held that applying the limitations period to bar a paternity claim for heirship does not violate equal protection or access to courts, as the claim was extinguished before any statutory amendment and a vested property right to be free from the claim accrued. The decision quashed the district court’s ruling and reinstated dismissal of the untimely claim.

Holdings

1. Section 95.11(3)(b)'s four-year limitation applies to any action relating to determination of paternity, including those brought in probate under § 732.108(2)(b) for intestate succession, because the statute's plain language covers all such actions and no probate code provision exempts them.
2. Application of § 95.11(3)(b) to Scruggs' paternity claim for heirship does not violate the constitution because her claim had been extinguished by a then-valid statute of limitations before any later amendment, and a vested property right to be free from the claim accrued.

Questions Presented

1. Whether Florida's four-year statute of limitations for paternity actions, § 95.11(3)(b), applies to paternity adjudications brought in probate under § 732.108(2)(b) for purposes of intestate succession.
2. Whether applying § 95.11(3)(b) to bar a paternity claim brought for heirship violates constitutional equal protection or access to courts.

Disposition

quashed_and_remanded