Monroy v. Prado
A Mexican national sued over a Florida car crash moved to quash substituted service made on the Florida Secretary of State as his statutory agent. The Sixth District affirmed the denial of the motion to quash, holding that the Hague Service Convention does not apply where the address of the person to be served is unknown, and that the 2022 amendments to section 48.161 are procedural/remedial and may be applied retroactively because the Legislature clearly expressed retroactive intent and retroactivity raises no constitutional problem.
Key facts
- Mexican national defendant was sued in Florida state court over a car crash; defendant's address was unknown to plaintiff.
- Defendant moved to quash substituted service that had been made on the Florida Secretary of State as his statutory agent under section 48.161.
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Why it matters
This is one of the first appellate decisions addressing the temporal reach of the 2022 overhaul of Chapter 48 in light of the 2025 curative legislation, and it squarely holds the amended section 48.161 is procedural and… — full analysis with a trial
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