by his failure to raise it in the trial court. Striking parallels can be found in the evolution of pleading requirements for venue and for the statute of limitations. In each, the longstanding legal principle represents a common-law procedural rule grounded in due process considerations; in each, the Florida Supreme Court has historically characterized the pleading requirement as an “essential element” or “jurisdictional fact” which must be alleged in a charging instrument; and in each, courts have for some time held that the failure to include such allegations is a fundamental defect which can be raised for the first time on appeal. After observing that the modern rules of discovery and relaxed pleading require urts as well. See Rodriguez v. State, 441 So.2d 1129 (Fla. 3d DCA 1983) (<HOLDING>); Farrar v. State, 42 So.3d 265, 265 (Fla. 5th
holding a statute of limitations defense does not deprive court of subject matter jurisdiction to the extent the statute of limitations may be considered in any sense a jurisdictional impediment it is one which can be waived holding statute of limitations is not jurisdictional and can be waived by a voluntary plea of guilty holding that the statute of limitations is nonjurisdictional and defendant expressly waived it observing in dicta that a statute of limitations defense should be raised no later than the trial holding that the aedpa statute of limitations is not jurisdictional holding statute of limitations is jurisdictional and may be raised at any time but noting other ohio appellate courts have held the statute of limitations is not jurisdictional and may be waived if not asserted at the trial level