The First District Court of Appeal certified as a question of great public importance the
issue of whether the jurisdictional nonclaim provisions of section 194.171, Florida
Statutes, apply to bar a civil action brought by the State that challenges a tax assessment
as void on the ground that the property assessed is immune from ad valorem taxation.
The trial court ruled that challenges to tax assessments brought by the State are subject to
the jurisdictional nonclaim provisions of section 194.171 and dismissed the State's
complaint because it was untimely under the statute. On appeal, the First District
reversed. The First District held that the jurisdictional nonclaim provisions of section
194.171 do not apply to challenges to tax assessments brought by the State that assert that
the property assessed is immune from ad valorem taxation, but certified the question to
this Court for review.