“One Unified Limited-Appearance Form” – A New Benchmark in Florida Family-Law Self-Help Documentation

Introduction

In In Re: Amendments to the Florida Family Law Rules of Procedure – Forms, No. SC2024-0003 (Fla. June 26, 2025), the Florida Supreme Court exercised its constitutional rule-making power to overhaul a significant group of standardised family-law forms. While form amendments tend to receive less public attention than rule amendments, they are the day-to-day tools by which self-represented litigants, lawyers, and trial judges navigate family disputes. By combining, refining, and modernising thirteen different forms, the Court addressed three persistent themes: (i) the growth of limited-scope legal representation, (ii) the need for plain-language, technology-friendly materials, and (iii) the mandate to keep forms in lockstep with existing substantive and procedural rules.

The Petition originated with the Florida Bar’s Family Law Rules Committee. After two publication cycles, stakeholder input (notably from the Family Law Section), and further in-house edits, the Court adopted the committee’s final proposal “with minor modifications.” The opinion is slim—only four substantive pages—but the embedded Appendix completely re-writes the affected forms. This commentary distils the practical and doctrinal consequences of the decision.

Summary of the Judgment

• Merger of Forms 12.900(b) & 12.900(c): The separate “Notice of Limited Appearance” and “Consent to Limited Appearance” are now one document—Notice of and Consent to Limited Appearance. Form 12.900(c) is deleted.
• Alignment with Rule 12.040(c)(1): The new form now tracks the rule’s terminology (“proceeding(s) or matter(s)”) and expands the issue checklist (parental responsibility, time-sharing, mediation).
• Attorney-Assisted Self-Help: Form 12.900(e) (“Acknowledgment of Assistance by Attorney”) abandons the prior requirement to name the drafting attorney, replacing it with a generic certification.
• Simplified Dissolution (Form 12.901(a)): Readability improvements, but the Court declined to deviate from Rule 12.105’s language on minor and dependent children.
• Child Support Worksheet (Form 12.902(e)): Adds a front-end case caption and a pre-worksheet “Gross Income Calculation” table to promote transparency in guideline math.
• Discovery Forms 12.930(a)–(c): Instructions continue to warn that failure to respond “may result in sanctions,” rejecting a proposed softer advisory on compelling responses.
• Mandatory Disclosure Certificate (Form 12.932): Stylistic re-write; reinforces the prohibition on filing sensitive financial documents unless ordered.
• Immediate Effect: The forms are “fully engrossed and ready for use” upon release, and a motion for rehearing does not toll the effective date.

Analysis

A. Precedents Cited

• Art. V, §2(a), Fla. Const. – Constitutional basis for the Court’s exclusive rule-making jurisdiction.
• Fla. R. Gen. Prac. & Jud. Admin. 2.140(b)(1) – Procedural pathway for committees to propose rule/form changes.
• Prior omnibus form updates: In re Amendments to the Florida Family Law Rules of Procedure—Forms, 300 So. 3d 102 (Fla. 2019); 297 So. 3d 660 (Fla. 2020). These cases illustrate the Court’s incremental style—large-scale form rewrites every few years.
• Unbundling lineage: Chandler v. Parker, 78 So. 3d 908 (Fla. 2011) (approving limited representation in family law); In re Amendments to Rules Regulating The Florida Bar re: Limited Scope Representation, 312 So. 3d 804 (Fla. 2021).

B. Legal Reasoning

The Court’s authority to amend forms is procedural, not substantive, yet the forms must faithfully implement existing substantive and procedural rules. Two analytical steps are evident:

1. Gap-filling & Harmonisation
   The Bar’s Family Law Section noted practical confusion when lawyers filed separate notices and consents for limited appearances. By merging the forms, the Court simplifies compliance with Rule 12.040(e) and minimises docket clutter. Harmonisation also explains the decision to mirror Rule 12.040(c)(1) language and to separate “parental responsibility” from “time-sharing,” reflecting their distinct statutory definitions post-2018 parenting-plan amendments.
2. Plain-Language & Technology Sensitivity
   The opinion references readability, adding mediation as a selectable issue, inserting a “Gross Income Calculation” table (a teaching tool), and removing the attorney’s name from form 12.900(e) to avoid inadvertent public disclosure through e-filing systems. These redesigns are driven by access-to-justice ideals rather than adversarial argument.

C. Impact

1. Unbundled Representation Normalised
   Combining notice and consent crystallises limited-scope representation as an accepted norm. Trial courts can now quickly confirm the scope of counsel’s responsibility, reducing needless motions to withdraw and hearing time.
2. Child-Support Litigation Streamlined
   The added income table helps litigants (and busy judges) identify where guideline numbers derive, reducing post-judgment enforcement battles centred on “hidden math.”
3. Mediation Visibility
   Listing “mediation” as a discrete limited-appearance topic acknowledges the explosion of court-ordered ADR. Practitioners may now confine their representation solely to the mediation session without assuming obligations for filings or hearings.
4. Discovery Clarity & Enforcement
   By retaining the “sanctions” warning (and rejecting a mild “you may compel” suggestion), the Court sends a message that family-law discovery is not optional.
5. E-Filing Privacy
   Removing the attorney’s identity from the “Acknowledgment of Assistance” and reiterating Rule 2.425’s confidentiality underscore the Court’s data-privacy emphasis in the e-courts era.
6. Future Rule Amendments
   Expect reciprocal amendments to the Rules Regulating The Florida Bar to cross-reference the new unified form, and possible CLE updates emphasising the change.

Complex Concepts Simplified

• Limited Appearance / Limited-Scope Representation: An attorney handles only a specified slice of the case (e.g., a mediation or a motion hearing) and is automatically terminated when that slice is complete.
• Form vs. Rule: Rules set out binding procedural law. Forms are Court-approved templates; they are not “law” but using them creates a rebuttable presumption of procedural compliance.
• Mandatory Disclosure (Rule 12.285): Automatic exchange of core financial documents—think of it as built-in “discovery lite” for family cases.
• Gross Income Table: A pre-worksheet area where each party copies the monthly figures from their financial affidavit; this simplifies line-by-line cross-checking during child-support hearings.
• “Engrossed” Form: A document fully edited into final publication format—no strikethroughs or underlines; ready for immediate use.

Conclusion

Though modest in length, the Court’s June 2025 opinion is a process milestone. By wedding notice and consent into a single limited-appearance form, the Court institutionalises unbundled representation, a practice central to modern access-to-justice strategies. Additional tweaks—captions, income tables, privacy edits—illustrate the Court’s ongoing responsiveness to practitioner and pro-se feedback, technological advancement, and statutory consistency. Practitioners should download the new PDF/Word templates immediately; clerks should purge obsolete versions; and anyone teaching family-law procedure should integrate these changes into syllabi and CLE materials. Small drafting moves, carefully mapped to the governing rules, often yield the largest courtroom efficiencies. This decision exemplifies that principle.