Florida's 2025 civil rules: why Rules 1.280 and 1.200 decide whether a case is ready for trial
By Lou Navarro · · 6 min read
In Florida state court, two rules now set the pace of a civil case from its first months: Rule 1.280 and Rule 1.200.
In 2024 the Florida Supreme Court rewrote Florida’s case management and discovery rules, effective January 1, 2025. It adopted the core amendments in May and refined them in December, before they took effect. The December opinion describes what it built:
“The amendments created a framework for the active case management of civil cases with a focus on adhering to deadlines established early based on the complexity of the case”
Deadlines established early. Rule 1.280 makes each side put its witnesses, documents, damages and insurance on the table at the start, without being asked. Rule 1.200 gives each case it covers a track and a schedule within months of filing, and holds everyone to it. Together they pull the work of the last months of a case into the first ones, which is why they decide whether a file is ready for trial when the court says it is time.
Which cases the amendments reach
“The amendments are effective January 1, 2025, at 12:01 a.m., and apply to all cases pending at that time, except that the requirements of rule 1.280(a) (Initial Discovery Disclosures) shall not apply to any action commenced before the effective date.”
The opinion kept case management orders already in effect, but sent extensions of their deadlines through the amended rules. So on an action commenced in 2025 or later, both rules apply in full; on an older one, the case management rules apply but the initial disclosure duty does not.
Rule 1.280: disclose first, then discover
Florida now has initial disclosures, modeled on the federal rule. Unless exempt or ordered otherwise,
“a party must, without awaiting a discovery request, provide to the other parties the following initial discovery disclosures”
The list: the people the party may use to support its claims or defenses, and what they know; the documents, electronically stored information and things it may use; a computation of each category of damages, with the documents behind it (noneconomic damages need no computation, but their categories and documents must be disclosed); and any insurance agreement that may cover a judgment. Impeachment-only material is carved out, and actions Rule 1.200(a) exempts are exempt here too. The clock is fixed, and the usual reasons for waiting are ruled out in advance:
“A party must make the initial discovery disclosures required by this rule within 60 days after the service of the complaint or joinder, unless a different time is set by court order.”
“A party is not excused from making its initial discovery disclosures because it has not fully investigated the case”
Your disclosures also open your own discovery. A June 2025 amendment made serving them the trigger, where the rule had spoken of disclosure obligations being satisfied:
“A party may not seek discovery from any source before that party's initial disclosures are served on the other party, except when authorized by stipulation or by court order.”
The same opinion pointed disputes over the quality of disclosures to a different rule:
“Incomplete and inadequate initial discovery disclosures are addressed in Florida Rule of Civil Procedure 1.380(d)”
And each disclosure is signed by an attorney of record, certifying after a reasonable inquiry that it is complete and correct when made.
Discovery is now limited to what is relevant and proportional. The rule allows discovery of any nonprivileged matter that is
“relevant to any party's claim or defense and proportional to the needs of the case”
and the Court’s commentary says that language is
“to be construed and applied in accordance with the federal proportionality standard”
The December 2024 opinion also amended Rules 1.340 and 1.350 so that objections state their grounds with specificity, and a production objection says whether anything is being withheld on its basis.
Then there is supplementation. A disclosure, or an answer to written discovery, must be supplemented or corrected
“in a timely manner if the party learns that in some material respect the disclosure or response is incomplete or incorrect”
Rule 1.380 supplies the consequence:
“If a party fails to provide information or identify a witness as required by rule 1.280(a) or (g), the party is not allowed to use that information or witness to supply evidence on a motion, at a hearing, or at a trial, unless the failure was substantially justified or is harmless.”
That sentence makes Rule 1.280 a trial rule. A witness left out of the disclosures in the second month of a case is a witness you may not be allowed to call in the twentieth.
Rule 1.200: the schedule is set early, and it holds
No later than 120 days after an action commences, the court assigns it to a streamlined, general or complex track, based on the judicial attention it needs rather than its dollar value. Complex cases proceed under Rule 1.201. In streamlined and general cases the court issues a case management order within the same 120 days. It sets the projected or actual trial period and deadlines for, at least, service, adding parties, fact and expert discovery, summary judgment motions, objections to pleadings, pretrial motions, and alternative dispute resolution. Then comes the sentence that changed Florida practice:
“Deadlines in a case management order must be strictly enforced unless changed by court order.”
An agreed order may still extend one deadline if the remaining dates are unaffected. Otherwise:
“If extending an individual case management deadline may affect a subsequent deadline in the case management order, parties must seek an amendment of the case management order, rather than submitting a motion for extension of an individual deadline.”
A motion to extend must show why and when the need became known, whether it is opposed, the exact new date and whether everyone agrees to it, and the steps and dates that will meet it, including confirmed availability of witnesses and experts. Rule 1.090’s general extension rule no longer governs these deadlines, and moving an actual trial period takes a motion under Rule 1.460. The old workaround is gone too:
“Notices of unavailability have no effect on the deadlines set by the case management order.”
The schedule a Florida case will be tried on is set in its first four months, and the case is measured against it from then on.
What ready for trial looks like under Rules 1.280 and 1.200
- You know when the action was commenced, so you know whether Rule 1.280(a) applies, and whether Rule 1.200(a) exempts the action.
- Initial disclosures went out within 60 days of service of the complaint or joinder, or by the court's date, signed by an attorney of record.
- They name every witness and document you expect to use, compute each category of economic damages, and include any insurance agreement.
- None of your discovery went out before your disclosures were served.
- Someone owns supplementation, and corrects a disclosure or response as soon as the case changes it.
- You know the track, the case management order is in the file, and every deadline it sets is on the calendar with a person responsible for it.
- Before asking for more time, you know whether the change moves later deadlines, and you can make the showing Rule 1.200(e)(3) requires.
- Whoever attends a case management conference knows the pending motions and has authority to agree to a schedule.
Your circuit’s administrative orders and your case management order control the details. Where this list and your order differ, follow the order.
Measure it on every matter
A checklist works when someone runs it on every open file, every week. Trial Commander’s Readiness Score™ is live for every firm. On a civil litigation matter it reads the work already recorded in the file and shows the evidence behind each point. Two of its checks bear directly on this article: whether the trial date the court set is recorded on the matter, and whether every open deposition has a date. A check with no data behind it is labelled as not yet tracked, never filled in with a guess. The deadlines a case management order sets can be entered on the matter’s deadline list, each with its own reminders.
The score measures how complete the preparation recorded in the file is. It does not decide whether anyone has complied with Rule 1.280 or Rule 1.200. The attorney reviews the file and decides what to do.
The Readiness Score measures preparation completeness only. It does not assess how the case will turn out. It is not legal advice.
Want a quick look first? The free Trial Readiness Self-Check asks 20 questions, including whether initial disclosures have been served and whether the case management order is in the file with every date on your calendar. Nothing you enter is saved or sent.
Sources
Lou Navarro is a practicing Florida, Texas and D.C. trial lawyer and built Trial Commander. This article is general information for lawyers and their staff. It is not legal advice. Check the current rules, your circuit’s administrative orders and your case management order before relying on it.