Fla. R. Civ. P. 1.110

General Rules of Pleading

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RULE 1.110. 	GENERAL RULES OF PLEADING
(a) 	Forms of Pleadings. Forms of action and technical forms
for seeking relief and of pleas, pleadings, or motions are abolished.
(b) 	Claims for Relief. A pleading which sets forth a claim for
relief, whether an original claim, counterclaim, crossclaim, or third-
party claim, must state a cause of action and must contain:
(1) 	a short and plain statement of the grounds on
which the court’s jurisdiction depends, unless the court already has
jurisdiction and the claim needs no new grounds of jurisdiction to
support it;
(2) 	a short and plain statement of the ultimate facts
showing that the pleader is entitled to relief; and
(3) 	a demand for judgment for the relief to which the
pleader deems the pleader entitled.

Relief in the alternative or of several different types may be
demanded. Every complaint will be considered to pray for general
relief.
(c) 	The Answer. In the answer, a pleader must state in short
and plain terms the pleader’s defenses to each claim asserted and
must admit or deny the averments on which the adverse party
relies. If the defendant is without knowledge, the defendant must so
state, and such statement will operate as a denial. Denial must
fairly meet the substance of the averments denied. When a pleader
intends in good faith to deny only a part of an averment, the pleader
must specify so much of it as is true and must deny the remainder.
Unless the pleader intends in good faith to controvert all of the
averments of the preceding pleading, the pleader may make denials
as specific denials of designated averments or may generally deny
all of the averments except such designated averments as the
pleader expressly admits. When the pleader does so intend to
controvert all of its averments, including averments of the grounds
on which the court’s jurisdiction depends, the pleader may do so by
general denial.
(d) 	Affirmative Defenses. In pleading to a preceding
pleading, a party must set forth affirmatively: accord and
satisfaction, arbitration and award, assumption of risk,
contributory negligence, discharge in bankruptcy, duress, estoppel,
failure of consideration, fraud, illegality, injury by fellow servant,
laches, license, payment, release, res judicata, statute of frauds,
statute of limitations, waiver, and any other matter constituting an
avoidance or affirmative defense. A pleading that sets forth an
affirmative defense must contain a short and plain statement of the
ultimate facts supporting the avoidance or affirmative defense.
When a party has mistakenly designated a defense as a
counterclaim or a counterclaim as a defense, the court, on terms if
justice so requires, must treat the pleading as if there had been a
proper designation. Affirmative defenses appearing on the face of a
prior pleading may be asserted as grounds for a motion or defense
under rule 1.140(b), provided this does not limit amendments
under rule 1.190 even if such ground is sustained.

(e) 	Effect of Failure to Deny. Averments in a pleading to
which a responsive pleading is required, other than those as to the
amount of damages, are admitted when not denied in the
responsive pleading. Averments in a pleading to which no
responsive pleading is required or permitted must be taken as
denied or avoided.
(f) 	Separate Statements. All averments of claim or defense
must be made in consecutively numbered paragraphs. The contents
of each paragraph must be limited as far as practicable to a
statement of a single set of circumstances, and a paragraph may be
referred to by number in all subsequent pleadings. Each claim
founded on a separate transaction or occurrence and each defense
other than denials must be stated in a separate count or defense
when a separation facilitates the clear presentation of the matter set
forth.
(g) 	Joinder of Causes of Action; Consistency. A pleader
may set up in the same action as many claims or causes of action
or defenses in the same right as the pleader has, and claims for
relief may be stated in the alternative if separate items make up the
cause of action, or if 2 or more causes of action are joined. A party
may also set forth 2 or more statements of a claim or defense
alternatively, either in 1 count or defense or in separate counts or
defenses. When 2 or more statements are made in the alternative
and 1 of them, if made independently, would be sufficient, the
pleading is not made insufficient by the insufficiency of 1 or more of
the alternative statements. A party may also state as many separate
claims or defenses as that party has, regardless of consistency and
whether based on legal or equitable grounds or both. All pleadings
must be construed so as to do substantial justice.
(h) 	Subsequent Pleadings. When the nature of an action
permits pleadings subsequent to final judgment, and the
jurisdiction of the court over the parties has not terminated, the
initial pleading subsequent to final judgment must be designated a
supplemental complaint or petition. The action must then proceed
in the same manner and time as though the supplemental
complaint or petition were the initial pleading in the action,

including the issuance of any needed process. This subdivision does
not apply to proceedings that may be initiated by motion under
these rules.
Committee Notes
1971 Amendment. Subdivision (h) is added to cover a
situation usually arising in divorce judgment modifications,
supplemental declaratory relief actions, or trust supervision. When
any subsequent proceeding results in a pleading in the strict
technical sense under rule 1.100(a), response by opposing parties
will follow in the same course as though the new pleading were the
initial pleading in the action. The time for answering and authority
for defenses under rule 1.140 will apply. The last sentence exempts
post judgment motions under rules 1.480(c), 1.530, and 1.540, and
similar proceedings from its purview.
2014 Amendment. The last two paragraphs of rule 1.110(b)
regarding pleading requirements for certain mortgage foreclosure
actions were deleted and incorporated in new rule 1.115.

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