Juan A. Salinas v. Sue Ann Ramsey, 234 So.3d 569

Federal district court in Southern District of Florida entered a money judgment for Salinas and Fuentes against Ramsey on September 23, 2004.
Federal Rule of Civil Procedure 69(a)(1) directs that execution/enforcement of a federal judgment in Florida follows Florida law.
In May 2015 the judgment creditors sought an order in federal court compelling Ramsey to complete a Florida post-judgment fact information sheet (Fla. R. Civ. P. 1.560, 1.977).
The district court denied the motion relying on Eleventh Circuit precedent (Balfour Beatty) holding that post-judgment discovery to collect a federal judgment is governed by Florida’s five-year statute for actions on a judgment, § 95.11(2)(a).
The Eleventh Circuit certified the question to the Florida Supreme Court, expressing doubt about Balfour in light of Burshan (Fla. 4th DCA).
The Florida Supreme Court held post-judgment discovery to collect a federal money judgment issued in Florida may be compelled during the twenty-year life of the judgment.

Issue	Plaintiff's Argument	Defendant's Argument	Held
What limitations period governs post-judgment discovery in federal court in Florida to collect a federal money judgment?	Salinas: post-judgment discovery is part of enforcement and may be conducted during the judgment’s enforceable life (twenty years).	Ramsey: such discovery is an “action on a judgment” and thus barred after five years under § 95.11(2)(a).	Held: Post-judgment discovery is not an "action" or an "action on a judgment"; it is part of execution/enforcement and may be compelled within twenty years of entry of the judgment.

Balfour Beatty Bahamas, Ltd. v. Bush, 170 F.3d 1048 (11th Cir. 1999) (held post-judgment discovery to collect a federal judgment was governed by Florida’s five-year statute on actions on a judgment)
Burshan v. Nat’l Union Fire Ins. Co., 805 So. 2d 835 (Fla. 4th DCA 2001) (rejected treating post-judgment collection efforts as an action on a judgment; endorsed enforcement through the judgment’s life)
Young v. McKenzie, 46 So. 2d 184 (Fla. 1950) (held post-judgment discovery is not an action on a judgment)
Massey v. Pineapple Orange Co., 100 So. 170 (Fla. 1924) (execution is a remedy and continuation of the original action, not a separate action)
Norwich Union Indem. Co. v. Willis, 168 So. 418 (Fla. 1936) (recognized Florida judgments have a twenty-year enforceable life)
Kiesel v. Graham, 388 So. 2d 594 (Fla. 1st DCA 1980) (court criticized by Burshan and disapproved to the extent inconsistent with this opinion)