Coto-Ojeda v. Samuel

(specially concurring).

I completely agree that under Florida Rule of Civil Procedure 1.140 the issue was waived. See Valjean Corp. v. Heininger, 559 So .2d 677, 678 (Fla. 3d DCA 1990).

In my view we should avoid use of the terms “general appearance” and “special appearance.” Concededly there are post-1948 cases like Coyne v. Coyne, 325 So.2d 407 (Fla. 3d DCA), cert. denied, 339 So.2d 1168 (Fla.1976), which explicitly analyze the issue in terms of “general appearance” versus “special appearance,” but the analysis is obsolete because the adoption of the Florida Rules of Civil Procedure in 1948…