A Florida appeals court lacks jurisdiction to review an untimely challenge to an injunction entered in a separate case that the challenger did not previously appeal. The Sixth District Court of Appeal said so on November 6, 2026, in Wilcoxon v. Wilcoxon, No. 6D2025-2701, in a per curiam opinion joined by Judges Wozniak, Smith and Brownlee. It affirmed a dissolution judgment and dismissed the injunction challenge.
What happened
The husband, representing himself, appealed a final judgment of dissolution of marriage from Highlands County. The court affirmed the judgment “in full without comment.” The same appeal also tried to raise an untimely challenge to an injunction “entered in a separate case, which he did not previously appeal.” The court dismissed that part of the appeal for lack of jurisdiction.
The rule on an untimely challenge to an injunction
The court cited section 59.081(2), Florida Statutes (2025), which says failure to invoke a court’s jurisdiction within the time the rules prescribe “shall divest such court of jurisdiction to review such cause.” The opinion gives no further reasoning.
What this does and does not mean
The opinion is about two pages. It does not say what kind of injunction was entered, who obtained it, when it was entered, or why the husband’s challenge was late, and it does not describe the arguments made against the dissolution judgment, which it affirmed without discussion. It says only that the injunction was entered in a separate case that was not appealed. It should not be read as deciding anything about the merits of either the injunction or the divorce. The opinion is not final until the time for a motion for rehearing expires and any timely motion is resolved.
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Read the opinion (PDF): Download the opinion (PDF)
Source: Wilcoxon v. Wilcoxon, No. 6D2025-2701 (Fla. 6th DCA Nov. 6, 2026). This article is general information, not legal advice.