The Supreme Court of Florida reminded us that a motion for rehearing is not required to preserve whether competent, substantial evidence supports a final judgment. Citizens of State v. Clark, 48 Fla. L. Weekly S217 (Fla. Nov. 9, 2023), No. SC22–0094, 2023 WL 7400723, at *2, n.7. A motion is required, however, “when a final order addresses substantive issues or reaches legal conclusions that have not been previously raised or challenged.” Id. at *2. A motion is also required “[t]o preserve for appeal a challenge to the failure of the trial court to make required findings of fact in the final judgment.” Fla. R. Civ. P. 1.530(a); Fla. Fam. L. R. P. 12.530(a).
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