Brightman v. Carter

Florida Rule of Civil Procedure 1.420(e) provides:

All actions in which it appears on the face of the record that no activity by filing of pleadings, order of court or otherwise has occurred for a period of one year shall be dismissed....

Case law has firmly established, however, that not just any “activity by filing of pleadings, order of court or otherwise” that “appears on the face of the record” will suffice; only that “record activity” that is reasonably calculated “to advance the cause to resolution” will avoid dismissal. See, e.g., Inman, Inc. v. Miami Dade Water and Sewer Authority, 489…