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In Re: Amendments to Florida Rules of Appellate Procedure

Docket SC2025-1458

Court of record · Indexed in NoticeRegistry archive · AI-enriched for research

AdministrativeGranted
Filed
Jurisdiction
Florida
Court
Supreme Court of Florida
Type
Opinion
Disposition
Granted
Citation
No. SC2025-1458 (March 19, 2026) (Corrected Opinion)
Docket
SC2025-1458

Original proceeding adopting proposed amendments to the Florida Rules of Appellate Procedure

Summary

The Florida Supreme Court adopted several amendments to the Florida Rules of Appellate Procedure proposed by The Florida Bar’s Appellate Court Rules Committee. The amendments update cross-references and wording, remove outdated references to the prior e-filing system, align paper filing and service requirements with recent changes to the Rules of General Practice and Judicial Administration, and revise certificate-of-service forms. The Court explained each change, incorporated consistency edits (for example replacing “pro se” with “unrepresented”), and set the effective date as July 1, 2026. No comments were received on the proposal.

Issues Decided

  • Whether to adopt proposed amendments to various Florida Rules of Appellate Procedure to conform to recent changes in the Rules of General Practice and Judicial Administration.
  • Whether to remove outdated definitions and references to the previous e-filing system and update service and filing procedures.
  • Whether to revise form and certificate-of-service language for consistency with recently amended rules.

Court's Reasoning

The Court concluded the amendments were necessary to remove outdated references and to harmonize the appellate rules with recently adopted changes to the Rules of General Practice and Judicial Administration, especially Rule 2.511 (e-filing portal), Rule 2.516 (service), and Rule 2.520 (documents). The Court relied on the Committee’s report and the absence of public comment, finding the proposed edits improved consistency and clarity of filing, service, and document-format requirements. Because the changes primarily update cross-references, terminology, and sample forms, the Court adopted them as proposed and set an effective date.

Authorities Cited

  • Florida Rule of General Practice & Judicial Administration 2.511
  • Florida Rule of General Practice & Judicial Administration 2.516
  • Florida Rule of General Practice & Judicial Administration 2.520
  • In re Amendments to Florida Rules of General Practice & Judicial Administration416 So. 3d 242 (Fla. 2025)
  • Article V, Section 2(a), Florida Constitution

Parties

Petitioner
The Florida Bar’s Appellate Court Rules Committee
Attorney
Dwayne Antonio Robinson, Chair, Appellate Court Rules Committee
Attorney
Joshua E. Doyle, Executive Director, The Florida Bar
Attorney
Heather Savage Telfer, Staff Liaison, The Florida Bar
Judge
MUÑIZ, C.J.
Judge
LABARGA, J.
Judge
COURIEL, J.
Judge
GROSSHANS, J.
Judge
FRANCIS, J.
Judge
SASSO, J.
Judge
TANENBAUM, J.

Key Dates

Opinion date
2026-03-19
Effective date of amendments
2026-07-01

What You Should Do Next

  1. 1

    Review internal filing procedures

    Courts, law firms, and self-represented litigants should review and update their filing and service checklists to reflect the new cross-references, terminology (e.g., ‘unrepresented’), and certificate-of-service formats.

  2. 2

    Update electronic filing guidance

    Clerks and e-filing vendors should ensure portals and instructions reflect the replacement of the old e-filing system references with Rule 2.511 and confirm how the electronic record is made available.

  3. 3

    Train staff and attorneys

    Provide brief training or memo to staff and attorneys about the July 1, 2026 effective date and the practical changes, such as removable paper clips for paper filings and updated service procedures.

Frequently Asked Questions

What did the Court decide?
The Court adopted amendments to several appellate rules to update terminology, remove outdated references to the old e-filing docket, and align filing and service procedures with recently amended general practice rules.
Who is affected by this decision?
Attorneys, litigants, court clerks, and anyone who files or serves documents in Florida appellate courts will be affected because filing, service, and document-format rules have been revised.
When do the new rules take effect?
The amendments become effective July 1, 2026 at 12:01 a.m., and a motion for rehearing will not change that effective date.
Do these changes change substantive appellate procedure?
No; the amendments mainly update cross-references, terminology, and formatting or service instructions to conform to other recently amended rules rather than change substantive appellate rights.
Can these amendments be reconsidered?
A motion for rehearing may be filed, but the Court stated that filing such a motion will not alter the effective date of the amendments.

The above suggestions and answers are AI-generated for informational purposes only. They may contain errors. NoticeRegistry assumes no responsibility for their accuracy. Consult a qualified attorney before relying on them.

Full Filing Text
Supreme Court of Florida
                            ____________

                         No. SC2025-1458
                           ____________

   IN RE: AMENDMENTS TO FLORIDA RULES OF APPELLATE
                     PROCEDURE.

                        March 19, 2026
                      CORRECTED OPINION

PER CURIAM.

     The Florida Bar’s Appellate Court Rules Committee filed a

report proposing amendments to Florida Rules of Appellate

Procedure 9.020 (Definitions), 9.045 (Form of Documents), 9.200

(The Record), and 9.420 (Filing; Service of Copies; Computation of

Time).1 Both the Committee and the Court published the proposal

for comment; no comments were received.

     We adopt the amendments to the rules as proposed. The

amendments address various changes that were made to the

Florida Rules of General Practice and Judicial Administration



     1. We have jurisdiction. See art. V, § 2(a), Fla. Const.; see
also Fla. R. Gen. Prac. & Jud. Admin. 2.140(b).
adopted in In re Amendments to Florida Rules of General Practice &

Judicial Administration, 416 So. 3d 242 (Fla. 2025). We discuss the

more significant rule amendments below.

     First, we delete subdivision (l) (E-filing System Docket) of rule

9.020 to remove a definition that became outdated with the recent

adoption of Rule of General Practice and Judicial Administration

2.511 (Florida Courts E-Filing Portal). See id. at 243.

     Next, under rule 9.045, we amend subdivision (a) to remove an

outdated cross-reference to Rule of General Practice and Judicial

Administration 2.520(a), and we amend subdivision (c) to require

that documents filed in paper form be held together by removable

paper clips, consistent with the recent amendments to rule 2.520

(Documents). See id. at 263.

     Rule 9.200(d)(5) is amended to remove an outdated reference

to the electronic e-filing system docket and an outdated reference to

download the electronic record based on the adoption of rule 2.511.

     Lastly, we make several changes to rule 9.420. In subdivision

(a)(1), we add a cross-reference to the exception for inmate filing in

subdivision (a)(2), providing “except as provided in subdivision (a)(2)

of this rule.” In addition, in subdivision (a)(2), the word


                                  -2-
“unrepresented” is substituted for the term “pro se” for consistency

with recent changes to the Rules of General Practice and Judicial

Administration. Next, a new subdivision (b) (Service of Filed

Documents) is added to provide that the filer of a document must

serve the document as provided by the rule unless a statute, rule,

or administrative order of this Court provides otherwise. Newly

relettered subdivision (c) is retitled from “Service” to “Service; How

Made,” and the provision is amended to remove the distinction

between service by a party or amicus curiae and by the clerk of the

court, with reference to Rule of General Practice and Judicial

Administration 2.516 (Service), and instead incorporating the

content from former subdivision (c) (Method of Service). Finally,

subdivision (d) is retitled from “Proof of Service” to “Certificate of

Service” and updates the certificate of service samples to conform to

the recent changes made to rule 2.516(f).

     Accordingly, we amend the Florida Rules of Appellate

Procedure as reflected in the appendix to this opinion. New

language is underscored; deleted language is stricken. The

amendments shall become effective on July 1, 2026, at 12:01 a.m.




                                  -3-
     It is so ordered.

MUÑIZ, C.J., and LABARGA, COURIEL, GROSSHANS, FRANCIS,
SASSO, and TANENBAUM, JJ., concur.

THE FILING OF A MOTION FOR REHEARING SHALL NOT ALTER
THE EFFECTIVE DATE OF THESE AMENDMENTS.

Original Proceeding – Florida Rules of Appellate Procedure

Dwayne Antonio Robinson, Chair, Appellate Court Rules
Committee, Miami, Florida, Joshua E. Doyle, Executive Director,
The Florida Bar, Tallahassee, Florida, and Heather Savage Telfer,
Staff Liaison, The Florida Bar, Tallahassee, Florida,

     for Petitioner




                                -4-
                              APPENDIX

RULE 9.020.     DEFINITIONS

     The following terms have the meanings shown as used in
these rules:

     (a)-(k)    [No Change]

      (l)     E-filing System Docket. The docket where attorneys
and those parties who are registered users of the court’s electronic
filing (e-filing) system can view the electronic documents filed in
their case(s).

                         Committee Notes

                              [No Change]


RULE 9.045.     FORM OF DOCUMENTS

      (a) Generally. All documents, as defined in Florida Rule of
General Practice and Judicial Administration 2.520(a), filed with the
court shallmust comply with Florida Rule of General Practice and
Judicial Administration 2.520 and with this rule. If filed in
electronic format, parties shallmust file only the electronic version.

      (b) Line Spacing, Type Size, and Typeface. The text in
documents shallmust be black and in distinct type, double-spaced.
Text in script or type made in imitation of handwriting shallis not
be permitted. Footnotes and quotations may be single-spaced and
shallmust be in the same size type, with the same spacing between
characters, as the text in the body of the document. Headings and
subheadings shallmust be at least as large as the document’s text
and may be single-spaced. Computer-generated documents
shallmust be filed in either Arial 14-point font or Bookman Old
Style 14-point font.




                                 -5-
     (c) Binding. Documents filed in paper format should be held
together by removable paper clips and shallmust not be stapled or
bound.

     (d)   [No Change]

      (e) Certificate of Compliance. Computer-generated
documents subject to word count limits shallmust contain a
certificate of compliance signed by counsel, or the party if
unrepresented, certifying that the document complies with the
applicable font and word count limit requirements. The certificate
shallmust be contained in the document immediately following the
certificate of service. The word count shall excludes words in a
caption, cover page, table of contents, table of citations, certificate
of compliance, certificate of service, or signature block. The word
count shall includes all other words, including words used in
headings, footnotes, and quotations. The person preparing the
certificate may rely on the word count of the word-processing
system used to prepare the document.


RULE 9.200.       THE RECORD

     (a) Contents.

           (1) -(2)   [No Change]

            (3) The parties may prepare a stipulated statement
showing how the issues to be presented arose and were decided in
the lower tribunal, attaching a copy of the order to be reviewed and
as much of the record in the lower tribunal as is necessary to a
determination of the issues to be presented. The parties must
advise the clerk of the lower tribunal of their intention to rely on a
stipulated statement in lieuinstead of the record as early in advance
of filing as possible. The stipulated statement must be filed by the
parties and transmitted to the court by the clerk of the lower
tribunal within the time prescribed for transmittal of the record.

     (b)-(c)      [No Change]


                                  -6-
     (d)   Preparation and Transmission of Electronic Record.

           (1)-(4)    [No Change]

           (5) The court must upload the electronic record to the
electronic filing (e-filing) system docket. Attorneys and those parties
who are registered users of the court’s e-filing system may
download the electronic record in their case(s).

     (e)-(f)     [No Change]

                           Committee Notes

                               [No Change]


RULE 9.420.      FILING; SERVICE OF COPIES; COMPUTATION OF
                 TIME

     (a)   Filing.

          (1) Generally. Filing maymust be accomplished in
conformity with the requirements of Florida Rule of General Practice
and Judicial Administration 2.525, except as provided in
subdivision (a)(2) of this rule.

           (2) Inmate Filing. The filing date of a document filed by
an pro seunrepresented inmate confined in an institution will be
presumed to be the date it is stamped for filing by the clerk of the
court, except as follows:

                 (A)-(B)    [No Change]

    (b) Service of Filed Documents. The filer of a document
must serve it as provided by this rule, unless:

          (1) a statute, rule, or administrative court order of the
Florida Supreme Court provides for a different method of service,
and the document is served under that method; or


                                  -7-
         (2) a statute, rule, or court order requires or permits
the document to be filed without being served.

     (b)(c) Service; How Made.

            (1) By a Party or Amicus Curiae. All documents must be
filed either before service or immediately thereafter. A copy of all
documents filed under these rules must, before filing or
immediately thereafter, be served on each of the parties. The lower
tribunal, before the record is transmitted, or the court, on motion,
may limit the number of copies to be served.

           (2) By the Clerk of the Court. A copy of all orders and
decisions must be transmitted, in the manner set forth for service
in rule 9.420(c), by the clerk of the court to all parties at the time of
entry of the order or decision, without first requiring payment of
any costs for the copies of those orders and decisions. Before the
court’s entry of an order or decision, the court may require that the
parties furnish the court with stamped, addressed envelopes for
transmission of the order or decision.

      (c) Method of Service. Service of every document filed in a
proceeding governed by these rules (including any briefs, motions,
notices, responses, petitions, and appendices) must be made in
conformity with the requirements of as required by Florida Rule of
General Practice and Judicial Administration 2.516(b). Service of
any document required to be served but not filed
contemporaneously must be made in conformity with the
requirements of Florida Rule of General Practice and Judicial
Administration 2.516, unless a court orders, a statute specifies, or
a supreme court administrative order specifies a different means of
service.

      (d) Proof of ServiceCertificate of Service. A certificate of
service by an attorney that complies in substance with the
requirements of Florida Rule of General Practice and Judicial
Administration 2.516(f) and a certificate of service by a pro se party
that complies in substance with the appropriate form below will be
taken asestablishes prima facie proof of service in compliance with
these rules. The certificate must specify the party each attorney

                                  -8-
represents. With respect to an unrepresented party, the following
sample certificates comply with this rule:

           (1)   By Pro SeUnrepresented Inmate:

I certify that on …..(date)….. I placed this document in the hands of
.....(here insert name of institution official)..... for mailing to
.....(here insert name(s) or names and service address(es)) used for
service)..... on .....(date)......


                                       …..(name)…..
                                       …..(address)…..
                                       …..(prison identification
                                       number)…..


           (2)   By Other Pro Se LitigantsUnrepresented Parties:

I certify that a copy hereof on …..(date)….. this document has been
furnished to .....(here insert name(s) or names and service
address(es) used for service)..... by ….. (here insert method of
service such as portal, .....(e-mail), (delivery), or (mail)..... on
.....(date)......


                                       …..(name)…..
                                       …..(address)…..
                                       …..(phone number)…..

     (e)   [No Change]

                          Committee Notes

                             [No Change]

                         Court Commentary

                             [No Change]



                                 -9-