DEPARTMENT OF REVENUE, ON BEHALF OF MADISON T. ADAMS
v.
OWEN HARRIS
AI-generated. These summaries, headnotes, and key points are machine-generated and may contain errors or omissions. Always verify against the full opinion text below. Not legal advice.
A hearing officer lacks authority to order genetic testing to determine paternity in child support proceedings when paternity has not been properly placed in controversy, good cause has not been established, and the matter involves contested paternity.
[1] A hearing officer in child support proceedings lacks authority to order genetic testing to determine paternity when the matter involves contested paternity, even if pater…
Previewing 1 of 1 headnotes on this case. FLexlaw’s editorially structured points of law — every proposition, pinpointed — are reserved for members.
Join FLexlaw to unlock all legal intelligenceThe Department of Revenue, on behalf of Madison Adams, sought to challenge a circuit court order approving a hearing officer's recommendation to compe…
The full statement of facts, procedural history, and disposition for this case are member content.
Join FLexlaw to unlock all legal intelligence© FLexlaw, Inc. — AI-generated enrichments are proprietary. All rights reserved.
Explore caselaw by topic → Browse Genetic Testing cases and more on FLexlaw
FIRST DISTRICT COURT OF APPEAL
STATE OF FLORIDA
_____________________________
No. 1D2025-0809 _____________________________
DEPARTMENT OF REVENUE, on behalf of MADISON T. ADAMS,
Petitioner,
v.
OWEN HARRIS,
Respondent. _____________________________
Petition for Writ of Certiorari—Original Proceedings.
October 15, 2025
PER CURIAM.
In this certiorari proceeding, the Department of Revenue, on behalf of Madison Adams, challenges an order approving the hearing officer’s recommendation to compel genetic testing to determine paternity of the minor child. We agree with the Department that the circuit court erred in approving the hearing officer’s recommendation. The child support proceedings did not properly place paternity in controversy, and Respondent did not establish good cause for the testing. Fla. Fam. L. R. P. 12.360(a)(1), (2); Fla. R. Civ. P. 1.360(a)(1), (2); State, Dep’t of Revenue ex rel. Chambers v. Travis, 971 So. 2d 157, 162 (Fla. 1st DCA 2007); Florida Dep’t Revenue ex rel. Corbitt v. Alletag, 156 So. 3d 1110, 1112 (Fla. 1st DCA 2015). Even if paternity was in controversy and
We GRANT the petition for writ of certiorari and QUASH the order compelling genetic testing.
ROBERTS, WINOKUR, and NORDBY, JJ., concur. _____________________________
Not final until disposition of any timely and authorized motion under Fla. R. App. P. 9.330 or 9.331. _____________________________
David C. Bearden, Department of Revenue, Crestview; James Uthmeier, Attorney General, and Toni C. Bernstein, Assistant Attorney General, Tallahassee, for Petitioner.
No appearance for Respondent.
Cases With Similar Vibessemantic neighbors from the corpus
Citator
Authorities Cited
- State v. Travis, 971 So. 2d 157 (Fla. 1st DCA 2007)
- Fla. Dep't of Revenue by v. Alletag, 156 So. 3d 1110 (Fla. 1st DCA 2015)
- Dede Nichols v. Moore, Stephens, Lovelace, P.A., 188 So. 3d 989 (Fla. 5th DCA 2016)