In Citizens Property Ins. Co. v. All Insurance Restoration Serv. (Fla. 3d DCA 2023), the Third District reminded us that interlocutory orders merge into the final judgment. The court had occasion to state this well-settled law because Citizens appealed an interlocutory order after the trial court had granted dismissal with prejudice (meaning that Citizens had won the case) in its favor. The Third District observed:

Our disposition of this appeal is guided by several enduring legal principles. It is well-settled that interlocutory orders merge into the final judgment. Oliver v. Stone, 940 So. 2d 526, 529 (Fla. 2d DCA 2006) (citation omitted) (“It is well established that a trial court may reconsider and modify interlocutory orders at any time until final judgment is entered. All interlocutory proceedings, however, are merged into and disposed of by the final judgment.”). Equally established is that appellate courts review “judgments, not statements in opinions.” Black v. Cutter Lab’ys, 351 U.S. 292, 297 (1956). As a result, only a party aggrieved by a judgment may ordinarily maintain an appeal. See Witt v. Baars, 18 So. 330, 330 (Fla. 1895) (“The bill having been dismissed as to the appellant Mary Witt, no relief whatever having been granted against her, or any liability adjudged against her or her estate, she cannot appeal; and the appeal as to her should be dismissed . . . .”); Colonnade 101 SE, Inc. v. Cordero, 194 So. 3d 446, 448 n.1 (Fla. 3d DCA 2016) (“[A] party cannot appeal an order which is wholly in its favor.”); Save Anna Maria, Inc. v. Dep’t of Transp., 700 So. 2d 113, 115 (Fla. 2d DCA 1997) (“The general rule is that parties cannot file proceedings to review an order of judgment in their favor.”); Credit Indus. Co. v. Remark Chem. Co., 67 So. 2d 540, 541 (Fla. 1953)(dismissing “an appeal from a decision favorable to the appellant”).

In All Insurance, the trial court’s order of dismissal did not grant any relief against the defendant, Citizens. In fact, the opposite was true. In dismissing the case with prejudice, the trial court simultaneously absolved Citizens of any liability and eliminated the possibility the case would be subsequently refiled. Further, reasoned the court, to the extent the trial court reserved jurisdiction to rule on the pending fee motion, “[a] trial court’s reservation of jurisdiction to award prevailing party attorney’s fees or impose sanctions are collateral matters to the main dispute.” HSBC Bank USA, Nat’l Ass’n for Fremont Home Loan Tr. 2005-B, Mortg.-Backed Certificates, Series 2005-B v. Buset, 216 So. 3d 701, 703 (Fla. 3d DCA 2017).