A trial court’s final order is not always the court’s last order; it is often the case that post-judgment motion practice will lead to later-issued orders. Since 1977, the majority of these post-judgment orders -- also called post-decretal orders -- have been appealed under Fla. R. App. P. 9.130(a)(4). Specifically, litigants have appealed post-decretal orders under Rule 9.130(a)(4)’s second sentence, which provided that “non-final orders entered after final order on authorized motions are reviewable by the method prescribed by this rule.”

No longer. The Florida Supreme Court, in its 2014 amendments to the Florida Rules of Appellate Procedure, deleted this sentence without comment.

Read the full article here:  https://www.floridabar.org/the-florida-bar-journal/appealing-post-judgment-orders-the-path-to-appellate-review-under-the-new-rule-9-130a4/