Clerk of the Court and Comptroller for the 13th Judicial Circuit, Hillsborough County v. Rangel
The Hillsborough Clerk appealed an order setting aside a final judgment of bond forfeiture on four cash bonds posted by a depositor after the criminal defendant was deported, and the denial of the Clerk's rule 1.540(b)(4) motion to vacate. The Second District affirmed, holding that section 903.26 applies to forfeiture and discharge of both surety and cash bonds (section 903.286 addresses only amounts withheld from the return of a cash bond), and that the sixty-day timing requirement in section 903.26 implicates case jurisdiction rather than subject-matter jurisdiction, so the Clerk waived the issue by never raising it below.
Key facts
- Hillsborough County Clerk appealed after the trial court set aside a final judgment of bond forfeiture on four cash bonds posted by a depositor when the criminal defendant was deported.
- The trial court granted a motion to discharge the bond forfeiture and denied the Clerk's rule 1.540(b)(4) motion to vacate that order.
- +2 more key facts with a free trial
Why it matters
The opinion applies the Florida Supreme Court's 2025 JJJTB decision to a statutory timing deadline, providing a useful template for arguing that statutory time limits are waivable 'case jurisdiction' rather than… — full analysis with a trial
🔒 Read the full opinion, holding & search the library
The full opinion PDF, the rules the court applied, our significance analysis, the background facts, and full-text search across every tracked Florida decision are available to members. Start a free 30-day trial — no credit card.
Not ready to sign up? Get the free Friday digest — the week's key Florida decisions by email, no login required.
Florida Court Tracker provides summaries of publicly available court opinions for informational and research purposes only. This is not legal advice and does not create an attorney–client relationship. Always verify holdings against the official opinion.