Coral Gables, FL – September 18, 2025 – Recent legislative changes to Florida’s service of process rules, which became effective on January 2, 2023, are already influencing judicial decisions. These reforms, developed by a Florida Bar task force that included Barakat + Bossa partner, Giacomo Bossa, were cited in a July 2025 ruling by the U.S. Bankruptcy Court for the Southern District of Florida in In re Mirror Trading International (PTY) Ltd., a case involving efforts to recover assets from an alleged international Bitcoin Ponzi scheme.
The court’s order addressed whether a plaintiff could serve a defendant—who lives a “laptop lifestyle” and is active online—via email and social media. While the court ultimately denied electronic service on individuals under current law, it acknowledged the 2022 legislative changes codified in Fla. Stat. § 48.102, which allow electronic service on businesses but not individuals. The opinion specifically referenced the Florida Bar Journal article authored by Giacomo Bossa and James B. Murphy, Jr., noting that the omission of individuals from the statute was intentional.
Judge Peter D. Russin wrote that the law “hasn’t quite kept pace with life,” observing that while electronic service would likely be more effective in such cases, courts cannot rewrite the rules. Instead, the opinion emphasized that any expansion to include individuals must come from the legislature or rule-making bodies.
“This case illustrates exactly why the task force’s work—and the ongoing dialogue about modernizing service rules—is so critical,” said Giacomo Bossa. The court’s reliance on our article shows that these changes are shaping judicial reasoning, even as the debate continues on how far they should go.”
The decision underscores the immediate impact of these reforms on litigation strategy and judicial interpretation, particularly in cases involving elusive defendants and digital commerce.
In addition to their successful track record as commercial litigators, Barakat + Bossa attorneys are actively involved in shaping the legal landscape. They contribute their expertise to various Florida Bar committees and other influential legal organizations, ensuring their continued impact on the evolution of laws and processes that affect businesses and individuals alike.
Click here to read the Bar article.
Click here to read the Court’s Opinion.
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