6. FLORIDA SESSION LAWS
6.1 Introduction
Bills passed by the Florida Legislature are enrolled as acts before presentment to the Governor. Acts that become law are reproduced in their entirety in the session laws. (Typically, and for the purposes of this rule, “acts” refers to such laws, which are published in the Laws of Florida.) A session law’s section numbers are identical to those previously appearing in its corresponding bill.
Statutes are a selected reproduction of the portions of each session law that are permanent in nature and general in applicability. A bill’s title and enacting clause are not reproduced in the statutes.
Generally, laws should be cited in the Florida Statutes. A session law should be cited only when it is the subject of discussion. Thus, if the text refers to an earlier legislative action, it is appropriate to cite to the session law because that is the product of the legislative action. Similarly, if a new law has not yet been codified, citing to the session law is required.
6.2 The Basic Form of Citation
(a) Names of Acts
Note that some session laws (and statutes) expressly designate a citable short title as the official name of the act. For example, sections 326.001-.006 of the Florida Statutes “may be cited as the ‘Yacht and Ship Brokers’ Act.’” § 326.001, Fla. Stat. (2024).
The legal title of an act is found in the language directly following the chapter and bill number. If the title is not reproduced in the statutes, it will be in the session laws.
Chapter 88-282, Laws of Florida, is entitled: “An act relating to the regulation of yacht brokers and salesmen by the department of business regulation . . . .”
Do not use the legal title to identify an act unless it is the official or popular name, e.g., the Uniform Trade Secrets Act. For acts without official or popular titles, see supra subsection (c).
When referring to an act by name or title, capitalize according to its appearance in the statutes.
(b) In Text
Refer to the act’s official or popular name unless describing a revision or amendment thereto, in which case the session law’s revising chapter should be identified.
Legal Documents:
► Florida’s Administrative Procedure Act was extensively revised by chapter 96-159, Laws of
Florida. The Act …
Scholarly Works:
► Florida’s Administrative Procedure Act was extensively revised by chapter 96-159, Florida Laws.
The Act …
(c) In Footnotes or Stand-Alone Citations
For scholarly works, Bluebook Rule 12.4(a) recommends that session laws without official or popular names be identified with the form “Act of [date of enactment].” However, enactment dates are not provided in the official Laws of Florida. Instead, use the secondary identification form recommended by the Bluebook, “Act effective [date of effectiveness].” The effective date is usually found in the last section of the session law. When this section reads, “This act shall take effect on becoming a law,” the effective date will be the date the act is either approved by the Governor or becomes law without his signature. The applicable date is normally indicated at the end of the session law.
Article III, section 9 of the Florida Constitution provides that when the legislature enacts a law without an effective date, the law goes into effect on the sixtieth day after adjournment sine die of the session of the legislature in which the law was enacted. In such cases, as well as when major provisions within the same law have differing effective dates, omit the official or popular name or the law.
The basic forms are:
Legal Documents – Session Laws 1956–Present:
► Ch. 88-282, Laws of Fla.
► Ch. 22-66, Laws of Fla.
Legal Documents – Session Laws Before 1956:
► Ch. 22000, Laws of Fla. (1943).
► Ch. 318, Laws of Fla. (1850).
Scholarly Works:
► [Name of Act / “Act effective …”], [chapter], [year] Fla. Laws [page number the Act begins on in
official Laws of Florida].
► Yacht and Ship Brokers’ Act, ch. 88-282, 1988 Fla. Laws 1506.
► Act effective July 1, 2022, ch. 22-62, 2022 Fla. Laws 456.
(d) Citing Internet Sources in Scholarly Works
Cite to the official Laws of Florida whenever possible. Note that some online sources—such as HeinOnline.org—reproduce official, accurately paginated session laws.
Depending on the year, however, some online sources of the Laws of Florida—such as the Florida Department of State’s website, laws.flrules.org—upload separate documents for each session law, with each document beginning on a page numbered “1.” These documents do not reflect the accurate page number in the official publication, which makes compliance with Bluebook Rule 12.4 unachievable. Thus, when an accurate page number cannot be found, cite to West’s Florida Session Laws Service or Lexis’s Florida Advance Legislative Service:
► Yacht and Ship Brokers’ Act, ch. 88-282, 1988 Fla. ALS (Lexis).
► Act effective July 1, 2022, ch. 22-66, 2022 Fla. Sess. Law Serv. (West).
6.3 Chapter Numbers
Chapter numbers appear at the head of each act that is approved by the legislature, signed by the Governor, and filed with the secretary of state. The secretary of state assigns these numbers in the order the acts are filed with the office. The first two digits of the chapter number represent the year of the legislation; the numbers after the hyphen indicate the numerical order in which the acts appear in the session laws. The numbers assigned in the session laws differ from those assigned in the Florida Statutes. Note that before 1957, the secretary of state used a different numbering system that numbered all session laws from the nineteenth century until 1956 in a consecutive numbering system. When citing to pre-1957 session laws in legal documents, include the year of the law. See supra Rule 6.2(c).
6.4 Sections of Acts
(a) Section Numbers
Section numbers in the Laws of Florida are not the same as – and do not correspond with – section numbers in the Florida Statutes. Session laws begin with section one and are numbered consecutively throughout.
Sometimes an act does not contain the intended location of codification in the Florida Statutes. For example, in the Laws of Florida, the Uniform Trade Secrets Act was divided into ten sections. After becoming a law, it was codified at sections 688.001-.009, Florida Statutes, but the location in the statutes was not established by the enactment.
More frequently, however, each act contains the intended location of codification in the Florida Statutes. For example, chapter 88-337, Laws of Florida, created the Family Policy Act. It provided as follows:
Section 13. Section 39.403, Florida Statutes, is amended to read: . . . .
The correct textual reference to the aforementioned section is “Section thirteen of the Act” or “Section 39.403, Florida Statutes,” but not “Section 39.403 of the Act.”
(b) Basic Form
Use the section symbol when referring to a specific section within the session law. Provide a pinpoint reference to the page in the Laws of Florida on which the material can be found. In scholarly articles, indicate the page on which the act begins as well. Include a parenthetical reference to the Florida Statutes if it is helpful to identify the specific portion of the section of the act under discussion.
Legal Documents:
► 1. Ch. 90-109, § 13, at 326, Laws of Fla.
► 2. Id. § 8, at 319 (amending § 713.135(1)(d), Fla. Stat. (1989)).
► 3. Ch. 89-114, § 2, at 310, Laws of Fla. (codified at § 287.133(3)(e)(1), Fla. Stat. (1989)).
Scholarly Works:
► 1. Ch. 90-109, § 13, 1990 Fla. Laws 307, 326.
► 2. Id. § 8, 1990 Fla. Laws at 319 (amending Fla. Stat. § 713.135(1)(d) (1989)).
► 3. Act effective July 1, 1989, ch. 89-114, § 2, 1989 Fla. Laws 307, 310 (codified at Fla. Stat. §
287.133(3)(e)(1) (1989)).
(c) Subsections of Acts
Sections of an act frequently have subsections that correspond to their anticipated location in the Florida Statutes. Retain the parentheses surrounding the subsection numbers (as well as those surrounding further subdivisions). A parenthetical indicating the location of the subsection in the Florida Statutes may be used if it is helpful to identify the subsection.
Legal Documents:
► Ch. 96-224, § 4(3), at 838, Laws of Fla. (codified at § 282.72(3)(a), Fla. Stat. (Supp. 1996)).
Scholarly Works:
► Electronic Signature Act of 1996, ch. 96-224, § 4(3), 1996 Fla. Laws 837, 838 (codified at Fla. Stat. § 282.72(3)(a) (Supp. 1996)).
6.5 Short Forms
(a) In Text
After the first reference to an act by its full name, it is permissible in subsequent references to simply use “Act” as a short-form reference.
► The Electronic Signature Act of 1996 was intended to boost confidence in electronic signatures.
… The Act aimed to reduce the number of forged electronic signatures.
(b) Use of “Id.”
“Id.” alone is sufficient to refer to an identical and immediately preceding citation. If, however, a subsequent citation refers to the same act but to a different section, include the section number, the session law reporter (except in legal documents), and the page on which the cited section begins.
Legal Documents:
► 1. Ch. 91-74, § 1, at 455, Laws of Fla. (amending § 43.29, Fla. Stat. (1989)); id. § 4, at 456 (to
be codified at § 760.51, Fla. Stat.).
► 2. Ch. 90-50, § 6, Laws of Fla.
► 3. Id.
► 4. Ch. 90-109, Laws of Fla.
► 5. Id. § 3, at 313 (amending § 713.03(1), Fla. Stat. (1989)).
Scholarly Works:
► 1. Act effective Oct. 1, 1991, ch. 91-74, § 1, 1991 Fla. Laws 455, 455 (amending Fla. Stat. §
43.29, (1989)); id. § 4, 1991 Fla. Laws at 456 (to be codified at Fla. Stat. § 760.51).
► 2. Act effective June 11, 1990, ch. 90-50, § 6, 1990 Fla. Laws 99, 113.
► 3. Id.
► 4. Ch. 90-109, 1990 Fla. Laws 307.
► 5. Id. § 3, 1990 Fla. Laws at 313 (amending Fla Stat. § 713.03(1) (1989)).
(c) Other Acceptable Short Citation Forms
In addition to the “id.” form, other short citation forms for Florida session laws may be used in scholarly works only. The following examples illustrate the use of acceptable short forms to refer to cited session laws:
► 1. Electronic Signature Act of 1996, ch. 96-224, 1996 Fla. Laws 837.
► 2. Act effective Oct. 1, 1996, ch. 96-159, 1996 Fla. Laws 147.
► 3. Electronic Signature Act § 5, 1996 Fla. Laws at 838.
► 4. Ch. 96-159, § 13, 1996 Fla. Laws at 174.
6.6 Parentheticals Indicating Statutory Change
(a) General Rule
When citing a session law, parenthetical references should assist the reader in finding the current statute in force. When the statute is no longer in force and there is no current version to cite, an explanatory parenthetical should instead indicate that the law has been repealed, amended, or transferred. See FSM Rule 5.7 for guidance on the citation format for Florida Statutes in these instances.
(b) Creation of New Statutes: “To Be Codified At”
If the cited act creates a new statute, and the official statutes containing the new act are not yet published, The Bluebook recommends indicating parenthetically where the cited act is to be codified. If relying upon the bill or session law for the citation, the parenthetical should read “(to be codified at § xxx.xx, Fla. Stat.)” in legal documents or “(to be codified at Fla. Stat. § xxx.xx )” in scholarly works, with no year for the statute indicated.
Legal Documents:
► Ch. 91-74, § 10, at 457, Laws of Fla. (to be codified at § 943.1715, Fla. Stat.).
Scholarly Works:
► Act effective Oct. 1, 1991, ch. 91-74, § 10, 1991 Fla. Laws 455, 457 (to be codified at Fla. Stat.
§ 943.1715).
(c) Creation of New Statutes: Codification Completed
Similarly, once the session law is codified in the official statutes, indicate parenthetically its location therein. Use the form “codified at” if indicating a historical fact or referencing the statute’s location as it appeared when first codified. Use the form “current version at” to reflect any amendments since enactment when referencing the current codification of the act. If the codification is to a supplement to the Florida Statutes, which came out in the even-numbered years prior to 1999, use the form “(Supp. 19xx)” for the year of the statute.
Legal Documents:
► Ch. 88-337, § 21, at 1773-76, Laws of Fla. (codified at § 415.504(4)(a), Fla. Stat. (1989)).
► Ch. 85-55, § 14(g), at 230, Laws of Fla. (current version at § 163.3202(2)(g), Fla. Stat. (1989)).
Scholarly Works:
► Ch. 88-337, § 21, 1988 Fla. Laws 1750, 1773-76 (codified at Fla. Stat. § 415.504(4)(a) (1989)).
► Ch. 85-55, § 14(g), 1985 Fla. Laws 207, 230 (current version at Fla. Stat. § 163.3202(2)(g)
(1989)).
(d) Amending Existing Law
If the cited session law amends an existing statute, a parenthetical may identify the amended statute as appropriate. Acts that amend an existing statute clearly indicate the statute being amended.
Legal Documents:
► Ch. 91-75, § 1, at 459, Laws of Fla. (amending § 581.192, Fla. Stat. (1989)).
Scholarly Works:
► Act effective July 1, 1991, ch. 91-75, § 1, 1991 Fla. Laws 459, 459 (amending Fla. Stat. §
581.192 (1989)).
See FSM Rule 5.7(c) for citations to statutes that have subsequently been amended.
(e) Amending and Recodifying Existing Law
If the session law amends an existing law and directs that it be codified at a new location, then indicate both the amended section as well as the new location in a single parenthetical.
Legal Documents:
► Ch. 91-74, § 3, at 456, Laws of Fla. (amending § 39.024(2)(b), Fla. Stat. (Supp. 1990), to be
codified at § 39.024(2)(c), Fla. Stat.).
Scholarly Works:
► Act effective Oct. 1, 1991, ch. 91-74, § 3, 1991 Fla. Laws 455, 456 (amending Fla. Stat. §
39.024(2)(b) (Supp. 1990), to be codified at Fla. Stat. § 39.024(2)(c)).
(f) Reenacting Law
If the session law reenacts a previously repealed statute, indicate the reenactment in a parenthetical.
Legal Documents:
► Ch. 91-187, § 3, at 1588, Laws of Fla. (reenacting § 270.22, Fla. Stat.).
Scholarly Works:
► Act effective Oct. 1, 1991, ch. 91-187, § 3, 1991 Fla. Laws 1587, 1588 (reenacting Fla. Stat. §
270.22).