CAMILLE GROOM, ET AL.
v.
ESTATE OF SUSAN NAUGHTON, ET AL.

Fla. 3d DCA | 2025-08-27
No. 2024-0720
Sanchez-Llorens, J., Fernandez, J., Lindsey, J., Bokor, J.
2025 FL 7371 Florida District Court of Appeal, Third District (2025)

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Holding

The trial court's findings of fact in a non-jury trial are presumed correct and will not be disturbed unless totally unsupported by competent and substantial evidence, clearly against the weight of the evidence, or induced by an erroneous view of the law.


Headnotes

[1] In reviewing a final judgment from a non-jury trial, the trial court's findings of fact are presumed correct and will not be disturbed unless totally unsupported by compe…

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Key Quotes

“In reviewing a final judgment rendered from a non-jury trial, the trial court's findings of fact are clothed with a presumption of correctness. We apply a clear error standard to the findings of fact, and a finding will not be disturbed unless it is totally unsupported by competent and substantial evidence, it is clearly against the weight of the evidence, or it was induced by an erroneous view of the law.”

Statement of the standard of review applied to non-jury trial judgments

Facts & Procedural History

This case involved a dispute between Camille Groom and others against the Estate of Susan Naughton and others, decided by the trial court in a non-jur…

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Opinion of the Court
Bokor

Third District Court of Appeal State of Florida

Opinion filed August 27, 2025. Not final until disposition of timely filed motion for rehearing.

No. 3D24-0720 Lower Tribunal No. 18-2109-CA-01

Camille Groom, et al., Appellants, vs. Estate of Susan Naughton, et al., Appellees.

An Appeal from the Circuit Court for Miami-Dade County, Migna Sanchez-Llorens, Judge.

Weinbaum P.A., and Lane Weinbaum (Coral Springs), for appellants. Clay Naughton, for appellees. Before FERNANDEZ, LINDSEY and BOKOR, JJ.

PER CURIAM.

Affirmed. See La Ley Sports Complex at City of Homestead, LLC v.

City of Homestead, 255 So. 3d 468, 469 (Fla. 3d DCA 2018) (“In reviewing

a final judgment rendered from a non-jury trial, the trial court's findings of fact are clothed with a presumption of correctness. We apply a clear error standard to the findings of fact, and a finding will not be disturbed unless it is totally unsupported by competent and substantial evidence, it is clearly against the weight of the evidence, or it was induced by an erroneous view of the law. We review the trial court's conclusions of law and application of law to the facts de novo.”) (internal citations omitted).

2


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