Cases from cite.case.law:

PETTIS, v. CHRISENTERY, a R. J. L., 229 So. 3d 870 (Fla. Dist. Ct. App. 2017)

. . . the reformation claim, concluding that it was barred by the 20-year statute of limitations in section 95.231 . . . Thus, Pettis’ reformation claim is not barred by section 95.231(2). See Moyer v. . . . The substance of section 95.23 was later transferred to section 95.231(2), Florida Statutes. . . .

SILVER SHELLS CORPORATION, v. ST. MAARTEN AT SILVER SHELLS CONDOMINIUM ASSOCIATION, INC., 169 So. 3d 197 (Fla. Dist. Ct. App. 2015)

. . . It also does not implicate section 95.231(2) because that statute applies “only to correct technical . . .

N. HARDEY M. v. SHELL, 144 So. 3d 668 (Fla. Dist. Ct. App. 2014)

. . . declaratory relief on the basis that it is barred by the statutes of limitations in sections 95.11 and 95.231 . . . Pursuant to the twenty[-]year restriction under Florida Statute 95.231[,] this cause of action is also . . . Moreover, the twenty-year limitation in section 95.231 does not bar the Hardeys’ count for declaratory . . . Section 95.231(2) “cannot validate conveyances made by persons who have no possessory interest in the . . . The trial court concluded that the Har-deys’ claim is barred by section 95.231 because the “the property . . .

DAVIS, v. HINSON, 67 So. 3d 1107 (Fla. Dist. Ct. App. 2011)

. . . As authority for this proposition, the court cited section 95.231, Florida Statutes (2010). . . . Nor does section 95.231(2), Florida Statutes (2010), cure the deed’s defects. . . . Section 95.231(2) is a curative provision. . . . Here, it seems that section 95.231(2) could cure the deed’s failure to adequately describe the specific . . . To find otherwise would mean section 95.231(2) could validate titles in every case where property is . . .

PRICE, f k a f k a f k a v. W. MINGO, E., 994 So. 2d 1249 (Fla. Dist. Ct. App. 2008)

. . . summary judgment on the ground that, as a matter of law, the present action is barred by sections 95.031, 95.231 . . .

PADRON WAREHOUSE CORP. a v. THE REALTY ASSOCIATES FUND III, L. P. III, a J., 377 F. Supp. 2d 1259 (S.D. Fla. 2005)

. . . . § 95.231 (quiet title), or a seven-year statute of limitations, see Fla. . . .

GLANVILLE, v. GLANVILLE,, 856 So. 2d 1045 (Fla. Dist. Ct. App. 2003)

. . . The applicable limitations statute, section 95.231, Florida Statutes, provides as follows: (1) Five years . . . Fain, 145 So.2d 858 (Fla.1962), Appellee argues that section 95.231 does not apply to a "void” deed. . . .

INGLIS, v. FIRST UNION NATIONAL BANK, f k a F. D. I. C. f k a E. S. H. s, 797 So. 2d 26 (Fla. Dist. Ct. App. 2001)

. . . for reformation of the deed was not barred by the 20-year statute of limitations set forth in section 95.231 . . . The version of section 95.231(2), Florida Statutes, in effect at the time of the recordation of the deed . . . claim to the property against the claimants under the deed or will or their successors in title. § 95.231 . . . See § 95.231(2), Fla. Stat. (2000). . . . appellee Colson’s claim here, are subject to the twenty-year limitation period set forth in section 95.231 . . .

MOORE v. SMITH- SNAGG, 793 So. 2d 1000 (Fla. Dist. Ct. App. 2001)

. . . Cowart carefully analyzed the law and concluded that even the twenty year statute of limitation [section 95.231 . . .

BOWMAN v. B. DAVIES, III,, 586 So. 2d 1332 (Fla. Dist. Ct. App. 1991)

. . . This latter ground was based upon section 95.231, Florida Statutes (1987). . . . Hattaway, 438 So.2d 456 (Fla. 5th DCA 1983) (section 95.231 is a curative statute not a traditional statute . . . 2d DCA 1961), cases which were decided in part based upon section 95.23, the predecessor to section 95.231 . . .

RIGBY, v. G. LILES, L. Co., 505 So. 2d 598 (Fla. Dist. Ct. App. 1987)

. . . Section 95.231(2), Fla.Stat. (1985), on the other hand, provides that “after 20 years from the recording . . . Section 95.231 is not a traditional statute of limitation but rather a curative act with a limitation . . . Cases falling under § 95.231 include actions to quiet title and to establish resulting trusts, void deeds . . . truth as between them and the grantees to the deeds, subject to the twenty year limitation period in § 95.231 . . .

A. STEIGMAN, D. D. v. B. DANESE, L. B. III,, 502 So. 2d 463 (Fla. Dist. Ct. App. 1987)

. . . Appellants take the position that the 20-year limitation period set forth in section 95.231(2), Florida . . . Coley is presently pending consideration by the Florida Supreme Court, Case No. 69,169. . s. 95.231(2 . . .

EARP SHRIVER, INC. v. C. EARP, 466 So. 2d 1225 (Fla. Dist. Ct. App. 1985)

. . . The final judgment recited that the corporation had waived reliance on section 95.231(1). . . . Section 95.231(1), Florida Statutes (1979), which first became effective January 1, 1975, reads as follows . . . Thus, the parties focus much of their attention on whether section 95.231(1) is a statute of limitations . . . The corporation admits that subsection (2) of section 95.231 which was carried forward from section 95.23 . . . One court has characterized section 95.231 as a curative act with a limitation provision. . . .

HOLLAND, v. J. M. HATTAWAY,, 438 So. 2d 456 (Fla. Dist. Ct. App. 1983)

. . . I concur with Judge Cowart’s conclusions in this case: (1) section 95.231(2), Florida Statutes (1981) . . . This case involves a contest between two land titles and the effect of a curative act (§ 95.231(2), Fla.Stat . . . northerly 25 feet of Lot 2 because (1) appellants’ action was barred by the statute of limitations (§ 95.231 . . . Section 95.-231(2) must be read with section 95.231(1), of which it is a part, and when this is done . . . We hold that if a wild deed has defects in its form or execution, section 95.231(2), Florida Statutes . . . Curative acts with limitations provisions (such as section 95.231, previously considered) rectify specified . . .

O. RAY, O. v. J. ROTELLA,, 425 So. 2d 94 (Fla. Dist. Ct. App. 1982)

. . . deeds of distribution may also benefit the record title as the basis for limitations (see §§ 95.22 and 95.231 . . .

YAWN v. C. BLACKWELL,, 343 So. 2d 906 (Fla. Dist. Ct. App. 1977)

. . . claim was actually for the imposition of a constructive trust, which imposition is barred by Section 95.231 . . . , Florida Statutes (1975). “95.231 Limitations where deed or will on record.— “(2) After 20 years from . . .

PADGETT v. A. STEIN, Jr., 406 F. Supp. 287 (M.D. Pa. 1975)

. . . 95.229(a); Food services set forth in 37 Pa.Code § 95.230(a); Personal hygiene set forth in 37 Pa.Code § 95.231 . . .