Background
The trial court entered a final Confirmation Judgment on October 9, 2025, confirming an arbitration award and imposing a money judgment against petitioners for $176,833.59. Pursuant to Florida Rule of Civil Procedure 1.560(c), the judgment ordered petitioners to complete and serve a Fact Information Sheet (Form 1.977) containing detailed financial information, including tax returns, bank statements, and other confidential documents, within 45 days unless the judgment was satisfied or post-judgment discovery was stayed.
Petitioners paid the full judgment amount plus accrued post-judgment interest ($178,787.67) on November 20, 2025—well within the 45-day period prescribed by the rule. Despite this full payment, respondent moved to compel petitioners to provide the Rule 1.560 discovery. The trial court granted the motion on April 16, 2026, and petitioners sought certiorari review.
The Court’s Holding
The Third District Court of Appeal held that the trial court departed from the essential requirements of law by compelling post-judgment discovery after the underlying judgment had been satisfied. The court emphasized that Rule 1.560(c) explicitly excuses judgment debtors from discovery obligations if “the final judgment is satisfied,” and petitioners plainly satisfied the Confirmation Judgment by paying it in full within the prescribed 45-day window.
The court rejected respondent’s argument that the judgment remained unsatisfied because it included reserved jurisdiction to liquidate future attorney’s fees. The court distinguished between a liquidated award of attorney’s fees—which constitutes an executable judgment—and a mere entitlement to fees without a determined amount, which is non-final and non-executable. Once petitioners paid all sums actually awarded in the Confirmation Judgment, Rule 1.560 discovery became premature because the judgment creditor had no remaining sums upon which to execute, levy, or garnish.
The court quashed the portion of the trial court’s order requiring petitioners to provide Rule 1.560 Discovery, finding that the order resulted in irreparable harm by compelling disclosure of sensitive financial information after the judgment’s obligation had been fully satisfied.
Key Takeaways
- Rule 1.560(c) post-judgment discovery is not required once a judgment is fully satisfied, even if the judgment reserves jurisdiction for future fee awards.
- Timely payment of all liquidated amounts within the 45-day period constitutes satisfaction of the judgment under Rule 1.560(c).
- An order granting entitlement to attorney’s fees without determining the amount is non-executable and cannot support post-judgment discovery obligations.
- Compelled disclosure of sensitive financial information after judgment satisfaction causes irreparable harm justifying certiorari review.
Why It Matters
This decision protects judgment debtors who promptly satisfy their obligations from post-judgment discovery burdens. Rule 1.560 is a mechanism for judgment creditors to locate and execute on assets to satisfy unsatisfied judgments—not a tool for extracting financial information after the judgment has been paid. The ruling clarifies that once a judgment debtor pays all liquidated amounts within the prescribed timeframe, the judgment creditor loses the statutory right to compel production of highly sensitive financial documents, including tax returns and bank statements.
The decision also establishes important limits on reserved jurisdiction for future fee awards. While courts may reserve jurisdiction to determine attorney’s fees, that reservation does not keep the underlying judgment “unsatisfied” for purposes of Rule 1.560 discovery once all currently liquidated amounts have been paid. This distinction prevents judgment creditors from using discovery as a collateral tool for financial investigation beyond the scope of judgment enforcement.