Wilson v. Scruggs

Summary

The Florida Supreme Court held that the four-year statute of limitations for paternity determinations under section 95.11(3)(b), Florida Statutes, applies to paternity adjudications brought in probate proceedings to establish intestate succession rights. The court rejected the argument that section 732.108(2)(b) creates a separate cause of action exempt from the limitations period. It also held that applying the limitations period to Scruggs’s claim was constitutional, quashed the district court’s decision, and directed reinstatement of the dismissal.

Holdings

1. Section 95.11(3)(b), Florida Statutes, applies to paternity actions brought in probate to determine heirship.
2. Section 732.108(2)(b) does not create an independent cause of action or exempt probate paternity adjudications from section 95.11(3)(b).
3. Applying section 95.11(3)(b) to Scruggs's paternity claim was not unconstitutional.

Questions Presented

1. Whether Florida's four-year statute of limitations for an action relating to determination of paternity applies when paternity is adjudicated in a probate proceeding to establish heirship.
2. Whether section 732.108(2)(b), Florida Statutes, creates an independent cause of action for establishing paternity for intestate succession that is exempt from the general paternity statute of limitations.
3. Whether applying section 95.11(3)(b), Florida Statutes, to Scruggs's paternity claim violated equal protection or access-to-courts provisions of the Florida Constitution or the Equal Protection Clause of the United States Constitution.

Disposition

quashed