DANIEL VALDEZ
v.
STATE OF FLORIDA

Fla. 3d DCA | 2026-06-04
No. 2025-0881
Rodriguez, J., Fernandez, J., Logue, J., Gordo, J.
2026 FL 6749 Florida District Court of Appeal, Third District (2026) Positive Treatment
Cited by 1 case

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Holding

A trial court's management of evidence falls within the court's broad discretion to regulate the course of proceedings, even when the judge has a duty of neutrality.


Headnotes

[1] A trial court's discretionary management and regulation of evidence in a proceeding falls within the court's broad authority, notwithstanding the judge's duty to maintain…

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Key Quotes

“While it bears reminding that every trial judge 'owes a duty of neutrality to the parties and may not favor one side or the other,' a principle that holds true whether in a proceeding before a jury or before the bench, we find the trial court's actions fell within the broad discretion afforded to the court to manage and regulate the course of the [evidence before it].”

Court's explanation of the standard for reviewing trial court management of evidence

Facts & Procedural History

Daniel Valdez appealed a decision from the Circuit Court for Miami-Dade County. The appeal involved the trial court's handling of evidence.…

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Opinion of the Court

Third District Court of Appeal

State of Florida

Opinion filed June 4, 2026. Not final until disposition of timely filed motion for rehearing.

No. 3D25-0881

Lower Tribunal Nos. 22-13258, F23-15301B

Daniel Valdez,

Appellant,

VS.

State of Florida,

Appellee.

An Appeal from the Circuit Court for Miami-Dade County, Ariel Rodriguez, Judge.

Carlos J. Martinez, Public Defender, and Shannon Hemmendinger, Assistant Public Defender, for appellant. James Uthmeier, Attorney General, and Lourdes B. Fernandez, Assistant Attorney General, for appellee. Before FERNANDEZ, LOGUE and GORDO, JJ. PER CURIAM.

Affirmed. See A.L.M. v. State, 390 So. 3d 207, 208 (Fla. 3d DCA 2024) ("While it bears reminding that every trial judge 'owes a duty of neutrality to the parties and may not favor one side or the other,' M.W. v. State, 263 So. 3d 214 (Fla. 3d DCA 2019), a principle that holds true whether in a proceeding before a jury or before the bench, we find the trial court's actions fell within the broad discretion afforded to the court to manage and regulate the course of the [evidence before it]." (footnote omitted)).

2


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