Twenty-second Amendment to the United States Constitution
Some argue that the 22nd Amendment and 12th Amendment bar any two-term president from later serving as vice president as well as from succeeding to the presidency from any point in the presidential line of succession. Others contend that the original intent of the 12th Amendment concerns qualification for "service" (age, residence, and citizenship), while the 22nd Amendment, concerns qualifications for "election", and thus (strictly applying the text) a former two-term president is still eligible to "serve" as vice president (neither amendment restricts the number of times an individual can be elected to the vice presidency), and then succeed to the presidency to serve out the balance of the term (though prohibited from running for election to an additional term).
Florida Legislature
On November 3, 1992, almost 77 percent of Florida voters backed Amendment 9, the Florida Term Limits Amendment, which amended the State Constitution, to enact eight year term limits on federal and state officials. Under the Amendment, former members can be elected again after a two-year break. In 1995, the U.S. Supreme Court ruled that states could not enact congressional term limits, but ruled that the state level term limits remain.