John Patrick, Petitioner v. Richard Hess, Respondents

Summary

The Court held that Florida's twenty-year statute of limitations applies to enforcement of a foreign judgment after the judgment is recorded and domesticated under the Florida Enforcement of Foreign Judgments Act. It reasoned that the Act treats a domesticated foreign judgment as a Florida judgment and that the relevant statutory provisions, read in pari materia, require application of the twenty-year period rather than the five-year period or the limitations period of the rendering state. The Court approved the Second District's decision and disapproved contrary decisions to the extent inconsistent. Justice Canady, dissenting and joined by Justice Polston, would have dismissed the case for lack of conflict jurisdiction because the cited decisions addressed different procedures and their contrary statements were dicta.