Travelers Casualty & Surety Co. of America v. Sidman, 103 So. 3d 900

Association sued Kirkwood for deed restriction violation; Kirkwood counterclaimed for slander of title.
Circuit court granted partial summary judgment that deed restrictions were unenforceable; appeal dismissed after settlement.
Consent money judgment entered December 29, 2010, with continued jurisdiction to enforce settlement terms.
Association assigned rights against its insurer Travelers to Kirkwood; Sidman appointed as plenary guardian of Kirkwood.
February 2011 Sidman moved to amend to add a third-party indemnification claim against Travelers under Rule 1.180; circuit court granted.
Travelers moved to dismiss amended third-party complaint; circuit court denied; Travelers petitioned for certiorari.

Issue	Plaintiff's Argument	Defendant's Argument	Held
Whether certiorari or prohibition is proper remedy.	Travelers argues certiorari is improper relief.	Sidman argues prohibition is appropriate due to jurisdictional excess.	Writ of prohibition appropriate; certiorari not proper.
Did circuit court exceed jurisdiction by allowing amended third-party complaint after consent judgment?	Milne principle that post-judgment filings exceed jurisdiction after finality.	Sidman relies on reservation of jurisdiction to enforce judgment.	Yes, exceeded jurisdiction; amended third-party complaint is a nullity.

Liberty Ins. Corp. v. Milne, 98 So.3d 613 (Fla. 4th DCA 2012) (trial court loses jurisdiction after final judgment)
State ex rel. Am. Home Ins. Co. v. Seay, 355 So.2d 822 (Fla. 4th DCA 1978) (jurisdictional limits after final decree)
Trucap Grantor Trust 2010-1 v. Pelt, 84 So.3d 369 (Fla. 2d DCA 2012) (certiorari standards; departure from essential requirements)
Reeves v. Fleetwood Homes of Fla., Inc., 889 So.2d 812 (Fla.2004) (certiorari framework; post-judgment remedies)
Fieselman v. State, 566 So.2d 768 (Fla.1990) (post-judgment appeal as remedy; certiorari limitations)