CHRISTIAN ALEXIS MEZA MANZANARES
v.
STATE OF FLORIDA

Fla. 1st DCA | 2022-12-28
No. 22-3565
Florida District Court of Appeal, First District (2022)

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Holding

The court dismissed the petition for writ of prohibition without addressing the merits.


Headnotes

[1] A judge's inflexible sentencing policy may constitute a basis for disqualification under Florida law.

[2] A judge exceeds the proper scope of inquiry and establishes grounds for disqualification when the judge attempts to refute charges of partiality rather than merely addres…

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Key Quotes

“When a judge has looked beyond the mere legal sufficiency of a suggestion of prejudice and attempted to refute the charges of partiality, he has then exceeded the proper scope of his inquiry and on that basis alone established grounds for his disqualification.”

Dissent citing Bundy v. Rudd as a potential ground for disqualification

Facts & Procedural History

Petitioner sought a writ of prohibition to disqualify the county court judge presiding over his criminal traffic case, alleging the judge had an infle…

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Opinion of the Court
Tanenbaum

PER CURIAM.

DISMISSED. M.K. THOMAS and TANENBAUM, JJ., concur; BILBREY, J., dissents with opinion.

_____________________________

Not final until disposition of any timely and authorized motion under Fla. R. App. P. 9.330 or 9.331. _____________________________

BILBREY, J., dissenting.

Petitioner has sought a writ of prohibition to disqualify the county court judge presiding in his criminal traffic case. I would issue an order to show cause directing the State to respond to the petition and respectfully dissent from the denial of the petition. See Fla. R. App. P. 9.100(h) (allowing an appellate court to direct a response when “the petition demonstrates a preliminary basis for relief”). The petition alleges that the county judge has an inflexible sentencing policy, which can be a basis to disqualify a trial judge. See Dunlevy v. State, 201 So. 3d 733, 736 (Fla. 4th DCA 2016). The petition also states another potential ground for disqualification. See Bundy v. Rudd, 366 So. 2d 440, 442 (Fla. 1978) (“When a judge has looked beyond the mere legal sufficiency of a suggestion of prejudice and attempted to refute the charges of partiality, he has then exceeded the proper scope of his inquiry and on that basis alone established grounds for his disqualification.”).

_____________________________

Jessica J. Yeary, Public Defender, and John J. Knowles, First Assistant Public Defender, Tallahassee, for Petitioner. Ashley Moody, Attorney General, and Robert “Charlie” Lee, Assistant Attorney General, Tallahassee, for Respondent.


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