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Florida Statute 95.22 - Full Text and Legal Analysis
Florida Statute 95.22 | Lawyer Caselaw & Research
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The 2025 Florida Statutes

Title VIII
LIMITATIONS
Chapter 95
LIMITATIONS OF ACTIONS; ADVERSE POSSESSION
View Entire Chapter
95.22 Limitation upon claims by remaining heirs, when deed made by one or more.—
(1) When any person owning real property or any interest in it dies and a conveyance is made by one or more of the person’s heirs or devisees, purporting to convey, either singly or in the aggregate, the entire interest of the decedent in the property or any part of it, then no person shall claim or recover the property conveyed after 7 years from the date of recording the conveyance in the county where the property is located.
(2) This section shall not apply to persons whose names appear of record as devisees under the will or as the heirs in proceedings brought to determine their identity in the office of the judge administering the estate of decedent.
History.—s. 1, ch. 10168, 1925; CGL 4659; s. 14, ch. 20954, 1941; s. 15, ch. 73-334; s. 16, ch. 74-382; s. 526, ch. 95-147.

F.S. 95.22 on Google Scholar

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Amendments to 95.22


Annotations, Discussions, Cases:

Cases Citing Statute 95.22

Total Results: 35  |  Sort by: Relevance  |  Newest First

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Overland Const. Co., Inc. v. Sirmons, 369 So. 2d 572 (Fla. 1979).

Cited 86 times | Published | Supreme Court of Florida

been filed. Moreover, the savings clause of section 95.022[10] extended the deadline for instituting existing
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Bauld v. JA Jones Const. Co., 357 So. 2d 401 (Fla. 1978).

Cited 67 times | Published | Supreme Court of Florida | 1978 Fla. LEXIS 4729

termination or completion of the contract. Section 95.022 provides that the revisions became effective
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Universal Eng'g Corp. v. Perez, 451 So. 2d 463 (Fla. 1984).

Cited 31 times | Published | Supreme Court of Florida | 1984 Fla. LEXIS 3026

also contained a savings clause, codified as section 95.022, Florida Statutes (1975), which provided: This
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Lamb Ex Rel. Donaldson v. Volkswagenwerk Aktienge-Sellschaft, 631 F. Supp. 1144 (S.D. Fla. 1986).

Cited 22 times | Published | District Court, S.D. Florida | 1986 U.S. Dist. LEXIS 27707

statute was accompanied by a savings clause, Section 95.022, which extended by one year the deadline for
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Alford v. Summerlin, 423 So. 2d 482 (Fla. 1st DCA 1982).

Cited 21 times | Published | Florida 1st District Court of Appeal

by that date, the action shall be barred." Section 95.022, Florida Statutes (Supp. 1974). It is immediately
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Purk v. Fed. Press Co., 387 So. 2d 354 (Fla. 1980).

Cited 18 times | Published | Supreme Court of Florida

been filed. Moreover, the savings clause of section 95.022 extended the deadline for instituting existing
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Homemakers, Inc. v. Gonzales, 400 So. 2d 965 (Fla. 1981).

Cited 16 times | Published | Supreme Court of Florida

commenced by that date, the action shall be barred. § 95.022, Fla. Stat. (Supp. 1974). Finally, the statute
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Brooks v. Cerrato, 355 So. 2d 119 (Fla. 4th DCA 1978).

Cited 16 times | Published | Florida 4th District Court of Appeal

law may be commenced before January 1, 1976. Section 95.022, Florida Statutes (Supp. 1974). The plaintiff
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Carpenter v. Florida Cent. Credit Union, 369 So. 2d 935 (Fla. 1979).

Cited 12 times | Published | Supreme Court of Florida

date to file suit and preserve their rights. Section 95.022, Florida Statutes (1975). The very nature of
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Perez v. Universal Eng'g Corp., 413 So. 2d 75 (Fla. 3d DCA 1982).

Cited 11 times | Published | Florida 3rd District Court of Appeal

administered without sale, denial or delay. [4] Section 95.022 entitled "Effective date; saving clause" provides:
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Boyce v. Cluett, 672 So. 2d 858 (Fla. 4th DCA 1996).

Cited 8 times | Published | Florida 4th District Court of Appeal | 1996 WL 148174

argue was in effect as of January 1, 1975 (see section 95.022), and at the time the alleged abuse occurred
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Worrell v. John F. Kennedy Mem. Hosp., 384 So. 2d 897 (Fla. 4th DCA 1980).

Cited 7 times | Published | Florida 4th District Court of Appeal

malpractice cases and that the saving clause (Section 95.022) was no indication of a retroactive intent
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Cates Ex Rel. Cates v. Graham, 427 So. 2d 290 (Fla. 3d DCA 1983).

Cited 6 times | Published | Florida 3rd District Court of Appeal

revised statutes contained a "savings clause," section 95.022, Florida Statutes (1975), which provided a
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Pullum v. Cincinnati, Inc., 458 So. 2d 1136 (Fla. 1st DCA 1984).

Cited 5 times | Published | Florida 1st District Court of Appeal

575. [5] This savings clause was codified as Section 95.022, Florida Statutes (1975). [6] Section 95.11(4)(b)
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Ruhl v. Perry, 390 So. 2d 353 (Fla. 1980).

Cited 5 times | Published | Supreme Court of Florida

sealed note from twenty years to five years. Section 95.022, enacted as part of the same legislative act
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Amerada Hess Corp. v. Morgan, 426 So. 2d 1122 (Fla. 1st DCA 1983).

Cited 4 times | Published | Florida 1st District Court of Appeal

...father's guardian conveyed their father's interest in the property without court approval, where the action was begun within seven years after their father's death; and we further held that the action was not defeated or barred by Sections 95.21 or 95.22, Florida Statutes (1975)....
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Jones v. Rainey, 386 So. 2d 1319 (Fla. 2d DCA 1980).

Cited 3 times | Published | Florida 2nd District Court of Appeal

law could be commenced before January 1, 1976. § 95.022, Fla. Stat. (1979). Appellant did not commence
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Meir v. Kirk, Pinkerton, Mcclelland, Savary & Carr, Pa, 561 So. 2d 399 (Fla. 2d DCA 1990).

Cited 3 times | Published | Florida 2nd District Court of Appeal | 1990 WL 60902

11(4)(a), it also enacted a savings clause, section 95.022, providing that "[t]his act shall become effective
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Wetmore v. Brennan, 378 So. 2d 79 (Fla. 3d DCA 1979).

Cited 3 times | Published | Florida 3rd District Court of Appeal

occurs. Section 36 of Chapter 74-382 codified as Section 95.022, Florida Statutes (1975) provided an effective
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MacRae v. Cessna Aircraft Co., 457 So. 2d 1093 (Fla. 1st DCA 1984).

Cited 2 times | Published | Florida 1st District Court of Appeal | 9 Fla. L. Weekly 2078, 1984 Fla. App. LEXIS 15252

court held that because the savings clause of § 95.022, Fla. Stat. extended by one year the deadline
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Egger v. Egger, 506 So. 2d 1168 (Fla. Dist. Ct. App. 1987).

Cited 1 times | Published | District Court of Appeal of Florida | 12 Fla. L. Weekly 1235, 1987 Fla. App. LEXIS 8220

...est in Lots 3 and 4, the other one-sixth being held by the grantee of Mary Egger, Mary having inherited the one-sixth interest upon George’s death. Plaintiffs appeal the trial court's finding which quieted title to Lots 5 and 6 in Mary pursuant to section 95.22, Florida Statutes (1985). 3 Plaintiffs argue, and we agree, that section 95.22 is not applicable to the instant case....
...Reversed and remanded to the trial court for further proceedings consistent herewith. Reversed and remanded. . Section 731.23, Fla.Stat. (1967). . This third party, who was joined as a defendant at the trial court level, is not a party to this appeal. . 95.22 Limitation upon claims by remaining heirs, when deed made by one or more.— (1) When any person owning real property or any interest in it dies and a conveyance is made by one or more of his heirs or devisees, purporting to convey, either sing...
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Durring v. Reynolds, Smith & Hills, 471 So. 2d 603 (Fla. 1st DCA 1985).

Cited 1 times | Published | Florida 1st District Court of Appeal | 10 Fla. L. Weekly 1545

Section 36, later codified in Florida Statutes as section 95.022, provided: This act shall become effective
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Purvis v. United Parcel Serv., 643 So. 2d 1161 (Fla. Dist. Ct. App. 1994).

Published | District Court of Appeal of Florida | 1994 Fla. App. LEXIS 9660, 1994 WL 549475

4 Arthur Larson, Law of Workmens’ Compensation § 95.22, at 17-126 (1994). Applying the above test to the
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Morrison v. Byrd, 72 So. 2d 657 (Fla. 1954).

Published | Supreme Court of Florida | 1954 Fla. LEXIS 1424

...vest title in Mrs. Morrison based upon the conveyance to her from one of the heirs, D. W. Byrd as above indicated. “It appears by the evidence that the original owner through whom plaintiffs claim died in 1933, prior to the effective date of F.S. § 95.22 [F.S.A.] which contains a provision to the effect that the seven year statute of limitations mentioned in the first paragraph of the statute shall not apply in a case where the person through whom claim is made died prior to the effective da...
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Garofalo v. Cmty. Hosp. of South Broward, 382 So. 2d 722 (Fla. Dist. Ct. App. 1980).

Published | District Court of Appeal of Florida | 1980 Fla. App. LEXIS 15655

professional. A saving clause was also provided in Section 95.022, Florida Statutes (Supp.1974) as follows: 95
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Maiden v. Cogdill, 428 So. 2d 376 (Fla. Dist. Ct. App. 1983).

Published | District Court of Appeal of Florida | 1983 Fla. App. LEXIS 19314

years. Chapter 74-382, Laws of Florida 1974. Section 95.022 was added to provide a saving clause; viz,
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Lugo v. Ford Motor Co., 611 F. Supp. 789 (S.D. Fla. 1985).

Published | District Court, S.D. Florida | 1985 U.S. Dist. LEXIS 18790

in 1974. Chapter 74-382, Laws of Florida. Section 95.022 provides that the revision became effective
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Creary v. Est. of Creary, 338 So. 2d 26 (Fla. Dist. Ct. App. 1976).

Published | District Court of Appeal of Florida | 1976 Fla. App. LEXIS 15543

...m’s undivided one third remainder interest in his father’s homestead, which had been conveyed without Mabel’s joinder. We therefore decide the first point in favor of appellant. The trial judge held appellant’s claim to have been barred by F.S. 95.22, F.S.1969 and F.S. 95.23, F.S.1969. F.S. 95.22, F.S.1969, provides: “When any person owning land, or any interest in lands in Florida, shall die, and a conveyance or conveyances shall be made by one or more of his or her heirs or devisees purporting to convey either singly or in the ag...
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Leila Williams, Etc. v. Barbara Williams (Fla. 3d DCA 2023).

Published | Florida 3rd District Court of Appeal

...of the personal representative where there were procedural irregularities or facts constituting fraud or bad faith”); but see, e.g., Egger v. Egger, 506 So. 2d 1168, 1168–69 (Fla. 3d DCA 1987) (determining that the statute of limitations in section 95.22, Florida Statutes (1985) doesn’t bar an action to quiet title initiated by heirs of the decedent)....
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Cates ex rel. Cates v. Graham, 427 So. 2d 290 (Fla. Dist. Ct. App. 1983).

Published | District Court of Appeal of Florida | 1983 Fla. App. LEXIS 18710

revised statutes contained a “savings clause,” section 95.022, Florida Statutes (1975), which provided a
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Race v. Moseley, 308 So. 2d 137 (Fla. Dist. Ct. App. 1975).

Published | District Court of Appeal of Florida | 1975 Fla. App. LEXIS 14492

...even years prior to the time this suit was filed. In any event, the claims of limitation and estoppel are such in this case that they cannot be decided upon summary judgment. The defendant’s argument that her title is perfected by reason of either § 95.22 or § 95.23 is untenable....
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Nash v. Asher, 342 So. 2d 1038 (Fla. Dist. Ct. App. 1977).

Published | District Court of Appeal of Florida | 1977 Fla. App. LEXIS 15095

provided by Section 95.022 Florida Statutes, 1975 applies to the present case. Section 95.022 Florida Statutes
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Brown v. Floyd, 202 So. 2d 215 (Fla. Dist. Ct. App. 1967).

Published | District Court of Appeal of Florida | 1967 Fla. App. LEXIS 4280

...e East half of SE 14 of Section 13, and not to the South half of SE 14 °f Section 13. The defendant-appellant, in support of his claim that he has a good title to the East half of the SE 14 of Section 13, Township 8 South, Range 16 East, cites F.S. § 95.22 as a bar to the appellee plaintiffs action: F.S. § 95.22, F.S.A. reads as follows: “95.22 Limitation upon claims by remaining heirs, when deed made by one or more....
...real estate, so conveyed. * * * ” Samuel B. Brown, the father of the parties hereto, died intestate in July 1927 and therefore the compiled General Laws of Florida, Section 4659, would be applicable to the instant case instead of the present F.S. § 95.22, F.S.A., if either were applicable....
...This deed, of necessity, included at least 40 acres of the homestead and, inasmuch as there had been no designation of which parcels comprised the homestead, the entire 80 acres' could as easily be claimed as part of the homestead. We therefore hold that neither F.S. § 95.22, F.S.A., nor its predecessor Section 4659, Compiled General Laws of Florida of 1927, afford a favorable defense to the defendant-appellant and that the chancellor was correct in so holding....
..., as against all persons who have not asserted by competent record title an adverse claim.” In the past there have been conflicting and near conflicting decisions in our Supreme Court decisions with respect to the application of both F.S. Sections 95.22 and 95.23, F.S.A. [or their predecessor statutes, 4659, 4660, and 4661 Compiled General Laws of Florida, 1927] but we believe we have supra expressed the prevailing rule in this state as to the application of F.S. § 95.22, F.S.A....
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Morgan v. Amerada Hess Corp., 357 So. 2d 1040 (Fla. 1st DCA 1978).

Published | Florida 1st District Court of Appeal | 1978 Fla. App. LEXIS 15792

Florida, but with a savings clause contained in § 95.022, Florida Statutes (1975), which would be applicable
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Vaughn v. Vaughn, 119 So. 2d 391 (Fla. Dist. Ct. App. 1960).

Published | District Court of Appeal of Florida | 1960 Fla. App. LEXIS 2456

..."The bill in this case was filed on the 3d day of April, 1928. The deed from Greenwood to Galt was made February 18, 1907, more than twenty years prior to the institution of the suit. Therefore, the provisions of chapter 10168, Acts of 1925, section 4659, C.G.L.1927 [F.S.A. § 95.22], op *395 erate as bar to the recovery by the complainants.” Appellant’s competent brief also relies on Restatement of the Law, Property, Vol....