E. G.
v.
L. D.

Fla. 6th DCA | 2026-08-14
No. 2025-2238
Evans, J., Stargel, J., Smith, J., Kamoutsas, J.
2026 FL 10483 Florida District Court of Appeal, Sixth District (2026)

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Holding

When an appellant omits points, positions, facts, and supporting authorities from an appellate brief, those matters are deemed waived, abandoned, or unworthy of consideration.


Headnotes

[1] An appellant's failure to include points, positions, facts, and supporting authorities in an appellate brief results in waiver of those arguments, and this principle appl…

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Key Quotes

“When points, positions, facts and supporting authorities are omitted from the brief, a court is entitled to believe that such are waived, abandoned, or deemed by counsel to be unworthy.”

Polyglycoat Corp. v. Hirsch Distribs., Inc., 442 So. 2d 958, 960 (Fla. 4th DCA 1983)

Facts & Procedural History

E. G. appealed a judgment from the Circuit Court for Charlotte County in a family law matter (case number 2023-DR-001075). The appeal was consolidated…

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Opinion of the Court

SIXTH DISTRICT COURT OF APPEAL

STATE OF FLORIDA

Case Nos. 6D2025-2238, 6D2025-2584

CONSOLIDATED

Lower Tribunal No. 2023-DR-001075

E. G.,

Appellant,

v.

L. D.,

Appellee.

Appeal from the Circuit Court for Charlotte County. Mary C. Evans, Judge.

August 14, 2026

PER CURIAM.

AFFIRMED. See Polyglycoat Corp. v. Hirsch Distribs., Inc., 442 So. 2d 958, 960 (Fla. 4th DCA 1983) (“When points, positions, facts and supporting authorities are omitted from the brief, a court is entitled to believe that such are waived, abandoned, or deemed by counsel to be unworthy."); Walker v. Est. of Yee, 376 So. 3d 758 (Fla. 4th DCA 2024) (applying Polyglycoat principles to a pro se litigant's brief). See also Applegate v. Barnett Bank of Tallahassee, 377 So. 2d 1150, 1152 (Fla. 1979) (“Without a record of the trial proceedings, the appellate court can not properly resolve the underlying factual issues so as to conclude that the trial court's judgment is not supported by the evidence or by an alternative theory.").

STARGEL, SMITH and KAMOUTSAS, JJ., concur.

E. G., Green Mountain, North Carolina, pro se.

L. D., Port Charlotte, pro se.

NOT FINAL UNTIL TIME EXPIRES TO FILE MOTION FOR REHEARING

AND DISPOSITION THEREOF IF FILED

2


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