In a recent decision, the Florida Supreme Court appeared to adopt a standard for certiorari review that further limits the availability of such review, continuing a trend that began during the 1960s. Noting that Florida courts have used the same three-prong standard since at least the middle of the last century, this Article traces the evolution of the standard from 1855, when the Supreme Court addressed it for the first time, until the Court’s apparent tightening of the standard in 2012. Although the Court used rather liberal language in the wording of the standard in its 1855 decision, it nevertheless explained that certiorari relief was of a limited nature. Over the next century, however, courts largely failed to provide a coherent definition or application of the standard. This resulted in some relaxation of the standard in its application by the appellate courts. That began to change in the 1960s, when courts began to apply the standard in a way that realized its purported limiting effect. Perhaps most often used to limit review is the prong that requires “material harm incapable of remedy by on appeal.” In 2012, the Florida Supreme Court may have tightened that prong even more. The Court cited with approval a Fourth District Court of Appeal decision that required a petitioner to show “financial ruin” to fulfill the irreparable- harm prong of the standard. This Article questions the wisdom of such a harshly limiting application by pointing out that pushing controversies into post-trial appeal rather than resolving them before trial may be an uneconomical use of judicial resources and shifts an unnecessary burden onto the litigants.