Brown v. Brown
Brown v. Brown, 169 So.3d 286 (Fla. 4th DCA 2015), 2015 WL 4269921
This decision serves as a nice reminder about a court's jurisdiction over real property. A circuit court in an estate proceeding cannot direct a personal representative to divide and distribute a decedent's real estate in another state, since the court lacks in rem jurisdiction to order and partition the sale of that real property. To properly partition out of state real property, a personal representative is required to open an ancillary action in that state. F.S. 64.022.