Florida Department of Health v. Woliner
In a Public Records Act enforcement suit, the trial court found the Department of Health committed technical chapter 119 violations but that Woliner failed to satisfy section 119.12's 5-business-day pre-suit notice requirement; it nonetheless awarded him $5,546.32 in costs and fees under the general cost statute, section 57.041. The First DCA reversed, holding that section 119.12 \u2014 as the more specific and more recently enacted statute \u2014 exclusively governs entitlement to costs in Public Records Act enforcement actions, so a claimant who fails the notice condition recovers nothing.
🔒 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.