But after a final judgment is rendered, a trial court lacks jurisdiction under chapter 61 to determine property rights, unless the final judgment reserves jurisdiction for a specific purpose regarding identified property. See Semko v. Semko, 537 So.2d 588 (Fla. 3d DCA 1988); Flanders v. Flanders, 516 So.2d 1090, 1091 (Fla. 5th DCA 1987) (absent facts supporting a reformation in equity, courts have no authority to modify a property settlement agreement). No reservation to redetermine property rights exists in the dissolution judgment under review in this case, and the trial judge specifically dealt with the parties' rights with regard to the two marital properties in question.
But after a final judgment is rendered, a trial court lacks jurisdiction under chapter 61 to determine property rights, unless the final judgment reserves jurisdiction for a specific purpose regarding identified property. SeeSemko v. Semko , 537 So. 2d 588 (Fla. 3d DCA 1988) ; Flanders v. Flanders , 516 So. 2d 1090, 1091 (Fla. 5th DCA 1987) [ ]. Encarnacion v. Encarnacion , 877 So. 2d 960, 963 (Fla. 5th DCA 2004) (footnotes omitted).
Given section 61.14's rather explicit failure to empower the court to modify property interests after final distribution, it follows that the trial court lacks jurisdiction under chapter 61 after a final judgment to decide property questions, unless the final judgment reserves such jurisdiction for a specific purpose regarding identified property, or is reversed, or is otherwise set aside. Semko v. Semko, 537 So.2d 588 (Fla. 3rd DCA), rev. denied, 542 So.2d 989 (Fla. 1988) (subsequent order requiring distribution of retirement plan constituted redetermination of property rights and improperly modifies a vested right); Flanders v. Flanders, 516 So.2d 1090, 1091 (Fla. 5th DCA 1987) ("In the absence of facts supporting a reformation in equity, courts have no authority to modify a property settlement agreement."); Brandt v. Brandt, 525 So.2d 1017, 1019 (Fla. 4th DCA 1988) ("where there is no reservation of jurisdiction the court obviously has no authority to entertain a petition to modify the provisions of a final judgment adjudicating property rights."); see also Carroll v. Carroll, 545 So.2d 338 (Fla. 4th DCA 1989); and DePeyster v. DePeyster, 629 So.2d 221 (Fla. 4th DCA 1993). And so, any attempt after a final judgment to modify an agreed property division must find its basis outside of chapter 61.