Florida Tenancy by the Entirety

A single Florida Supreme Court ruling from 2001 is the reason a married couple's jointly owned property is presumed protected from either spouse's individual creditors — without either spouse checking a box.

A rule dating to 1829

Under Fla. Stat. § 689.15, a conveyance to two or more people creates a tenancy in common — no survivorship — unless the instrument expressly provides for the right of survivorship. The statute's history traces back to a Florida law from 1829, though it excepts one thing from the start: estates by the entirety. That exception is where married couples get treated very differently from everyone else.

The 2001 case that set the presumption

In Beal Bank, SSB v. Almand & Associates (2001), the Florida Supreme Court held that any real or personal property jointly owned by a married couple is presumed to be held as tenants by the entirety, unless the couple has expressly indicated otherwise. This is a genuinely different starting point from the ordinary rule: instead of needing to affirmatively create survivorship, a married couple gets it by default, and it takes an express indication to the contrary to opt out.

Complete protection, not just survivorship

Tenancy by the entirety does more than pass property to the survivor without probate. Because Florida law treats spouses as a single owner rather than two people each holding a separable half-interest, a judgment creditor of just one spouse can't reach entireties property at all. Ordinary joint tenancy with right of survivorship doesn't offer this: each JTWROS owner holds a separable share that their own individual creditor can reach and force to sale. Only a judgment against both spouses together can reach entireties property.

A statutory fix for individually owned property

Before 1943, a spouse who individually owned real property and wanted to convert it to entireties ownership with their spouse had to route the transfer through an intermediary third party — there was no way to deed it directly to both spouses and have that work. Fla. Stat. § 689.11 fixed this: it lets one spouse deed property directly to both spouses as tenants by the entirety, satisfying the unities of time and title without an intervening conveyance.

Not a community property state

Despite the strength of this presumption, Florida is not a community property state. Married couples own what they individually title; property doesn't automatically become shared jointly-owned property just because the couple is married. The Beal Bank presumption applies specifically to property that's already jointly titled in both spouses' names — it doesn't reach into one spouse's individually titled assets.

Married couples can still opt out

Because the presumption can be overcome by an express indication otherwise, a married couple who wants ordinary joint tenancy, or a tenancy in common, instead of entireties ownership can still arrange that — but it requires clear, affirmative language showing that intent, not just silence on the deed.

A different route for keeping real estate out of probate

Tenancy by the entirety and ordinary joint tenancy aren't the only ways to avoid probate for Florida real estate. See our guide to the Florida Lady Bird deed for a tool that works without adding anyone as a co-owner at all — and the constitutional limit that can affect it.

Florida tenancy by the entirety — frequently asked questions

How old is Florida's tenancy in common default statute?

Florida Statute 689.15, which makes tenancy in common the default for a conveyance to two or more people unless survivorship is expressly stated, traces its history back to a Florida law from 1829.

What did the Beal Bank case establish for Florida married couples?

In Beal Bank, SSB v. Almand & Associates (2001), the Florida Supreme Court held that any real or personal property jointly owned by a married couple is presumed to be held as tenants by the entirety, unless the couple has expressly indicated otherwise.

How does tenancy by the entirety protect against creditors in Florida?

Because spouses are treated as a single owner rather than two people each holding a separable share, a creditor with a judgment against only one spouse cannot reach entireties property at all — complete protection that ordinary joint tenancy with right of survivorship does not provide.

Does Florida Statute 689.11 help convert individually owned property to entireties ownership?

Yes. It lets a spouse who individually owns real property deed it directly to both spouses as tenants by the entirety, satisfying the time and title unities without routing the transfer through an intermediary conveyance.

Is Florida a community property state?

No. Married couples in Florida own what they individually title, and entireties ownership must be deliberately created or presumed under the Beal Bank standard — property is not automatically shared simply because a couple is married.

This page provides general guidance only and is not legal advice. Figures and rules are based on Florida statute (Fla. Stat. § 689.15, § 689.11) and published Florida court decisions, verified per our methodology. Confirm how a specific deed is actually titled with the county Clerk of Court or a licensed Florida attorney before acting.