THOMAS L. SMIDDY; SANTOS M. GARCIA; OMAR MORGAN; FRANCISCO GONZALEZ; ADELAIN ARAGON; MAGDALINE ROBERTS; OQUELLY GONZALEZ; FERNANDO MARRERO; REYES SANCHEZ; PATRICK THEARD; RAYMOND Y. JOHNSON; SIMON ARTEAGA; MICHAEL HIGGINS; AND JULIO DELGADO, PETITIONERS,
v.
THE STATE OF FLORIDA, RESPONDENT
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Petitioners charged with DUI sought writs of certiorari to quash a circuit court decision that reversed county court orders dismissing their charges. The county court found that police violated department policy by selectively failing to videotape DUI suspects in bad faith to avoid exculpatory evidence, but the appellate division reversed. The District Court of Appeal granted certiorari, finding the appellate court impermissibly reweighed evidence contrary to the proper standard of review.
The appellate division departed from the essential requirements of law by impermissibly reweighting and reevaluating the evidence instead of interpreting it in a manner most favorable to sustaining the trial court's ruling. If any competent substantial evidence supports the trial court's ruling, it must be sustained irrespective of the reviewing court's view of its appropriateness.
[1] An appellate court departs from the essential requirements of law when it impermissibly reweighs and reevaluates the evidence presented to the trial court.
[2] Appellate courts must interpret evidence in a manner most favorable to sustaining the trial court's ruling.
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Join FLexlaw to unlock all legal intelligence“[A]ppellate courts must interpret the evidence in a manner most favorable to sustain the trial court's ruling.”
Establishes the proper standard for appellate review of trial court factual findings
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Join FLexlaw to unlock all legal intelligenceIn 1990, petitioners were arrested and charged with DUI in county court. The arresting officers did not videotape the administration of sobriety tests…
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BASKIN, Judge.
Petitioners, defendants below, seek writs of certiorari to quash a decision of the circuit court, appellate division, reversing county court orders dismissing charges against defendants. We grant the petitions.
In 1990, petitioners were arrested and charged in county court with driving under the influence [DUI]. The officers processing the petitioners did not videotape the administration of petitioners’ sobriety tests. Petitioners filed motions to dismiss the pending charges, arguing that they had been denied due process: Petitioners asserted that in 1990, contrary to existing policy, the officers had ceased videotaping all DUI suspects, and instead were selectively videotaping drivers in cases where the tape would aid in conviction but not videotaping drivers where the tape would lead to acquittal.
During the two-day hearing on the motion, the parties presented extensive testimony. Petitioners offered testimony of City of Miami Police Department [Department] DUI supervisors who stated that the Department’s policy was to videotape all DUI arrestees, and that all officers under supervision had been instructed to carry out that policy. The state asserted that the Department’s new sobriety test made the videotaping unnecessary. Some officers testified that they stopped videotaping drivers after the former sobriety test was abandoned; other officers testified that they continued to videotape drivers although they ceased performing that test. Another officer testified that he videotaped drivers when he was “in the mood.” Despite testimony from some officers that the videotaping equipment at the north police station was inoperable, a video taken with that equipment, by another officer, was introduced.
The county court determined that the officers had violated Department policy by failing to videotape drivers and that the officers intended to avoid gathering exculpatory evidence, conduct the court found to be a demonstration of the officers’ bad faith. After ordering a case-by-case review of all the cases, the court entered orders dismissing the charges against petitioners. The state appealed the orders to the circuit court, appellate division.
The circuit court reversed the orders, finding that the Department did not violate any state or federal due process rights. The court found that the evidence indicated: 1) that videotaping was no longer a policy because the crimper test was not in use; 2) that the police had no duty to preserve evidence; and 3) that their bad faith actions were irrelevant. Petitioners seek certiorari review of the appellate division’s decision.
We hold that the circuit court, in reaching its decision, impermissibly reweighed and reevaluated the evidence, and thus departed from the essential requirements of law. Horatio Enter., Inc. v. Rabin, 614 So. 2d 555 (Fla. 3d DCA 1993); State v. Burke, 531 So. 2d 416 (Fla. 4th DCA 1988). “[A]ppellate courts must interpret the evidence in a manner most favorable to sustain the trial court’s ruling.” Horatio Enter., Inc., 614 So. 2d at 556. If there is any competent substantial evidence to support the trial court’s ruling it must be sustained irrespective of the reviewing court’s opinion as to its appropriateness. Helman v. Seaboard Coastline R.R. Co., 349 So. 2d 1187, 1189 (Fla.1977); Burke. A review of the record demonstrates the existence of ample evidence supporting the trial court’s conclusions; the circuit court was not at liberty to substitute its views for those of the trial court. We therefore grant the petitions for writs of certiorari, quash the circuit court opinion, and reinstate the orders dismissing the charges against petitioners.
Certiorari granted; decision quashed.
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Maurer v. State, 668 So. 2d 1077 (Fla. 5th DCA 1996)…ing that circuit court is prohibited from reweighing facts presented at suppression hearing, and that circuit court may not attribute more significance to certain facts than county court in order to reach contradictory conclusion). Smiddy v. State, 627 So. 2d 1257 (Fla. 3d DCA 1993) is similar to the instant case. In Smiddy the district court reversed an order of the circuit court sitting in its review capacity in a DUI ease. 627 So. 2d 1257. There, the district court held that a circuit court, in reviewing a…1 / 2
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Sunby v. State, 845 So. 2d 1006 (Fla. 5th DCA 2003)…to the circuit court, should have been presumed correct. See Maurer v. State, 668 So. 2d 1077 (Fla. 5th DCA 1996). If there was competent substantial evidence to support the county court’s ruling, it should have been sustained. See Smiddy v. State, 627 So. 2d 1257 (Fla. 3d DCA 1993). Like the District Court of Appeal, the circuit court sitting in its appellate capacity cannot reweigh the evidence and choose to believe a state witness which the county court chose not to believe. Hart v. State, 661 So. 2d 54 (F…
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State v. Kirby, 752 So. 2d 36 (Fla. 5th DCA 2000)…tness, and the circuit court must interpret the evidence in a manner most favorable to sustaining the trial judge’s ruling. Maurer v. State, 668 So. 2d 1077, 1078-79 (Fla. 5th DCA 1996) (county court is sole arbiter of credibility); Smiddy v. State, 627 So. 2d 1257, 1258 (Fla. 3d DCA 1993) (DCA reversed order of circuit court sitting in its review capacity; circuit court may not reweigh the evidence or substitute its judgment for that of the lower court). See also, Citrus County v. [*38] Florida Rock Indus., I…
Previewing 3 of 5 citing cases — full citator treatment, depth of discussion, and citing context are member features.
Join FLexlaw to unlock all legal intelligenceAuthorities Cited
- Helman v. Seaboard Coast Line R.R. Co. & William A. Cagle, 349 So. 2d 1187 (Fla. 1977)
- Horatio Enters., Inc. v. Rabin, 614 So. 2d 555 (Fla. 3d DCA 1993)
- State v. Brown, 531 So. 2d 416 (Fla. 3d DCA 1988)
- Form v. Raphael Steinhardt, 531 So. 2d 416 (Fla. 3d DCA 1988)