In Mann v. Chief Judge of the Thirteenth Judicial Circuit, 696 So. 2d 1184 (Fla. 1997), the court cited our previous opinion in Administrative Order Fourth Judicial Circuit (Division of Courts), 378 So. 2d 286, 286 (Fla. 1979), for the proposition that the Florida Constitution "only requires the establishment of subject matter divisions, i.e., criminal, civil, juvenile, probate, and traffic." Accordingly, the Court concluded that the drug court division at issue in Mann was properly created by administrative order. 696 So. 2d at 1185. The court further noted that it would place "too great a burden upon the efficient administration of justice . . . to require every specialized section of the major subject-matter divisions of a court to be approved by local rule." Id. In light of our reasoning in Mann and the senior judge utilization statistics for the circuit, we conclude that the use of senior judges to relieve overcrowding of the civil and criminal dockets in the Seventeenth Judicial Circuit does not constitute a complex case division that requires approval by local rule. Thus, the senior judge assignments are proper via administrative order of the chief judge.