What Does ''Subject Matter Jurisdiction'' Mean ?
In General Dynamics Corp. v. Paulucci, 797 So. 2d 18 (Fla. 5th DCA 2001), the Fifth District characterized the issue before it as one of the trial court's "subject matter jurisdiction." See 797 So. 2d at 21.
The court concluded that framing the issue as one of subject matter jurisdiction is inaccurate.
Subject matter jurisdiction "means no more than the power lawfully existing to hear and determine a cause." Cunningham v. Standard Guar. Ins. Co., 630 So. 2d 179, 181 (Fla. 1994) (quoting Malone v. Meres, 91 Fla. 709, 109 So. 677, 683 (Fla. 1926)).
It "concerns the power of the trial court to deal with a class of cases to which a particular case belongs." Id.
Rather, the issue presented by the certified question is more aptly described as one of the trial court's "continuing jurisdiction." Cf. Finkelstein v. North Broward Hosp. Dist., 484 So. 2d 1241, 1243 (Fla. 1986) (finding that the trial court has continuing jurisdiction to entertain a post-judgment motion for attorney's fees).
In Kinser v. Crum, 823 So. 2d 826, 827 (Fla. 1st DCA 2002), the First District cited the Third District's decision in Buckley Towers with approval and held that the trial court had jurisdiction to enforce a settlement agreement entered into by the parties.