To file a motion for final judgment in Florida, you draft two documents — the motion itself, which asks the court to enter judgment, and a separate proposed final judgment, which is the order you want the judge to sign — then file both through the Florida Courts E-Filing Portal and serve every other party. The motion has to identify the procedural basis for the request (default, summary judgment ruling, or trial verdict), spell out the exact relief sought, and attach evidence supporting any damages figures. Depending on the type of damages and whether the other side objects, the court may rule on the papers or set an evidentiary hearing before signing.
Start With the Right Procedural Basis
The content of your motion depends entirely on how you got to this point. Filing under the wrong theory, or without the documentation that theory requires, is one of the fastest ways to have the motion denied.
After a Clerk’s Default
If the defendant was properly served and never filed a responsive pleading, you likely already asked the clerk to enter a default under Florida Rule of Civil Procedure 1.500.1FindLaw. In re Amendments to Florida Rules of Civil Procedure 1.440 and 1.500 A clerk’s default is not a judgment. It only locks the defendant out of contesting liability. You still need a motion for final judgment to get the court to award specific relief.
The damages type matters here. If the amount can be calculated directly from a contract or promissory note — a liquidated sum — the court can often enter judgment on the papers. Unliquidated damages, such as pain and suffering or lost business profits, almost always require an evidentiary hearing even after a default.
After Summary Judgment
If the court granted a motion under Rule 1.510, it has decided the legal issues but has not necessarily signed a judgment.2The Florida Bar. Amendments to Florida Rule of Civil Procedure 1.510 and New Florida Rule of Civil Procedure 1.202 The winning party submits a proposed final judgment that incorporates the court’s ruling into an enforceable order. Reference the order granting summary judgment and its date in the motion.
After Trial
A jury verdict or a judge’s bench-trial findings do not become enforceable on their own. The prevailing party submits a proposed final judgment that translates the verdict into a formal order saying who recovers, from whom, and how much. Post-trial motions often also address pre-judgment interest, taxable costs, and attorney’s fees where a contract or statute authorizes them.
What the Motion Itself Must Contain
The motion is the request. It should state the specific legal basis up front. After a default, cite Rule 1.500 and attach proof the clerk’s default was entered. After summary judgment, reference the order granting the motion. After trial, reference the verdict or the court’s findings.
Spell out the relief you want. For money, that means a specific dollar figure broken into principal, pre-judgment interest, and costs. For injunctive relief, describe exactly what the defendant must do or stop doing. Vague requests invite objections.
Back the numbers up. Every assertion about damages, interest, or costs should be supported by an attached affidavit or documentation. Courts routinely reject motions where figures appear without support.
Drafting the Proposed Final Judgment
The proposed final judgment is a separate document filed alongside the motion. It is the actual order the judge will sign. Judges rarely draft these from scratch, so the quality of your draft directly determines the quality of the order you get. A poorly drafted proposed judgment can create enforcement problems that cost more to fix than the original litigation.
Money Judgment Requirements
For a monetary award, identify by full legal name the party recovering and the party against whom judgment is entered. Break the total into components: principal, pre-judgment interest, and taxable costs.
Pre-judgment interest in Florida is calculated at the rate established under Florida Statutes Section 55.03, which the state’s Chief Financial Officer adjusts annually.3MyFloridaCFO. Judgment Interest Rates Check the current year’s published rate before drafting. Using the wrong rate is a common error that triggers objections.
Standard Florida practice includes the phrase “for which let execution issue” immediately after the total. This language authorizes enforcement through writs of execution without a separate motion. Omitting it can delay collection. Include signature lines for the judge and the clerk.
Also make sure the judgment contains enough identifying information about the debtor — legal name, last known address, and the identification numbers referenced in Florida Statutes Section 55.203 — because you will need them later to file a judgment lien certificate against real property.4Florida House of Representatives. Florida Code 55.203 – Judgment Lien Certificate Content, Filing, and Indexing
Filing and Serving Through the E-Portal
Florida requires attorneys to file electronically through the Florida Courts E-Filing Portal, and the portal is the primary filing method for self-represented litigants as well.5Florida Courts E-Filing Portal. About the Florida Courts E-Filing Authority The portal itself is free. You pay any required court fees and a small processing fee through the system.6Florida Courts Help. Filing Your Forms
Log into the portal, select the existing case number, and upload the motion and the proposed final judgment as separate PDFs. Once the clerk accepts the filing, the system transmits the documents to every party registered for electronic service. Any party not registered for e-service must be served the old way, by mail or hand delivery. Keep your proof of service. Judges check that every party received the motion before ruling.
What Happens After You File
The opposing party has a window to respond or object. Even a defaulted defendant can challenge the proposed judgment on grounds like incorrect damages or lack of personal jurisdiction. The judge reviews the motion and any response to confirm the procedural requirements are met and the law supports the requested relief.
If damages are unliquidated or the opposing party raises a legitimate objection, expect a hearing. You present evidence establishing your damages or addressing the objection. Once satisfied, the judge signs the proposed final judgment and the clerk records it. Collection efforts, including writs of execution against the debtor’s assets, can begin from that point.
Deadlines That Start the Day Judgment Is Entered
Two clocks start running when the judgment is signed, and both matter whether you won or lost.
A motion for rehearing or motion for new trial under Florida Rule of Civil Procedure 1.530 must be served within 15 days after the judgment is filed. These motions typically argue the court made a legal error or that newly discovered evidence changes the outcome. A timely-filed rehearing motion can delay finality and reset the clock for appeal.
A notice of appeal under Florida Rule of Appellate Procedure 9.110 must be filed within 30 days of the judgment’s rendition.7Florida Appellate Rules. Rule 9.110 Appeal Proceedings To Review Final Orders Of Lower Tribunals Courts enforce this deadline strictly, and missing it usually forfeits the right to appeal entirely. If you are the judgment creditor, a pending appeal does not automatically stop enforcement, but the appellant can seek a stay by posting a supersedeas bond.
Know the Limits Before You Try to Collect
A signed judgment does not guarantee payment. Federal law restricts what a judgment creditor can take, and some income is effectively off-limits.
The Consumer Credit Protection Act caps wage garnishment on ordinary civil judgments at the lesser of 25% of the debtor’s disposable earnings or the amount by which weekly disposable earnings exceed 30 times the federal minimum wage.8U.S. Department of Labor. Fact Sheet #30: Wage Garnishment Protections of the Consumer Credit Protection Act Child support and alimony judgments carry higher limits.
Social Security benefits are generally exempt from execution, levy, attachment, or garnishment under Section 207 of the Social Security Act.9Social Security Administration. SSR 79-4: Levy and Garnishment of Benefits The narrow exceptions cover delinquent federal taxes and child support or alimony enforcement. An ordinary civil money judgment fits neither, so if the debtor’s main income is Social Security, your collection options are sharply limited.
If the debtor files bankruptcy, the automatic stay halts collection the moment the petition is filed, whether or not you received notice. Violating the stay, even by accident, can result in sanctions. Whether the judgment survives discharge depends on the underlying debt, and non-dischargeable categories such as fraud judgments usually require an adversary proceeding in the bankruptcy court to preserve your right to collect.