Given the Standards of Review Criminal Appeals Rarely Involve Questions of Fact Decided by a
Raise Your Standards: A Practitioner's Guide to the Effective Use of Appellate Standards of Review
Litigants are often tempted to address the merits of a legal issue, without reference to the applicable appellate standard of review. Nevertheless, litigators should get-go identify and alert the presiding court to the applicable standard of review because information technology defines the scope of the appellate court'southward inquiry, the level of deference to be paid to the lower tribunal's ruling,1 and controls the event of the outcome or appeal.
Many litigators unknowingly lose ground before they have even filed their find of appeal. Trial courts are well aware of the lens through which a ruling will be reviewed and their decisions are tailored to comply with the standard of review long earlier any appeal is taken. An constructive practitioner contemplates which standard of review will utilize to each legal issue in a case because doing and then helps 1) identify whether an issue is worth pursuing; 2) ensure that an result is preserved for appeal; 3) predict the way a trial court volition dominion on the issue; and 4) and shed light on how to persuasively frame the outcome during each stage of litigation. Without a house agreement of the standards of review, a litigant will exist hard-pressed to succeed on a motion or properly develop the record for success on appeal.
Categories of Trial Court Rulings
Constructive use of a standard of review is informed past the rationale behind the occasion that gave rise to the demand for the standard. The standards are a judicial construct, designed to efficiently and judiciously place and right harmful legal mistake.
Essentially, all trial courtroom rulings autumn into ane of 3 categories: 1) conclusions of law; 2) findings of fact; and three) discretionary decisions.ii Because trial court judges preside alone and observe the presentation of show, the constabulary presumes that a trial court is in a better suited position to oversee example management, weigh evidence, resolve factual disputes, and make credibility determinations in the cases over which they preside,3 merely their decisions are not binding and practice not have precedential effect over other courts or cases.
Conversely, an appellate court'south chief tasks are to review the actions of a lower tribunal for "harmful" or "reversible" legal fault, translate the law, found uniform precedent and ensure compatible application of the law throughout the state, and administrate justice.4 An appellate courtroom does non reweigh show, resolve factual disputes, or brand credibility determinations because appellate judges do not have the benefit of observing the presentation of evidence at trial. Instead, they review the cold, hard record on entreatment, which by and large consists of pleadings, courtroom filings, transcripts, and copies of exhibits.5 Because Florida's appellate judges sit down in panels of three or more,6 the individual ability of an appellate courtroom judge is more express than that of a trial court judge. This limitation reduces the potential for error and allows for appellate court decisions to have bounden, precedential effect over lower courts.
The Relationship Between Trial Court Rulings and Appellate Standards of Review
At that place are only three categories of trial court rulings and just a handful of the most common standards of review that apply in civil proceedings.7 Each category confers upon the trial court a lesser or higher degree of judgment. The level of deference paid past the appellate court is in directly proportion to the level of judgment conferred upon the trial court. Despite a trunk of well-settled police on each standard, the applicable standard is not always credible or articulate.8In that location may be many iterations of just one standard. It may be hard to distinguish between a question of law and a question of fact, or the nature of the trial court ruling may be mixed. As a result, there are times when it is advisable for the parties to disagree every bit to the applicable standard, or fifty-fifty one iteration of the standard, and to nowadays persuasive argument to the courtroom every bit to why i standard or some other should apply.9 To ignore an unfavorable standard will but cause the party to lose the opportunity to persuade the court to utilize a more favorable standard, or to provide the court with an analysis of the legal issue through the advisable lens.x
Every bit discussed more fully below, to successfully navigate through murky legal problems in which the standard is unclear, information technology is critically important that a litigant understand the theory behind each category and standard to effectively identify and use the correct standard.
The Most Common Appellate Standards of Review in Civil Cases
In civil cases, an appellate issue may be reviewed under one of the following most mutual appellate standards of review (or any combination thereof): 1) de novo; 2) competent, substantial evidence; 3) abuse of discretion; four) harmless error; or five) the Tipsy Coachman doctrine.xi
Standards of review serve a number of of import functions. Bated from their belittling value, they have practical value as well. Florida law requires that practitioners include in their appellate briefs "[a]rgument with regard to each issue, with citation to appropriate regime, and including the applicative appellate standard of review."12 The Florida Supreme Courtroom has underscored the importance and office of the standards of review in appellate proceedings:
"An appellate court'due south commencement obligation when reviewing a lower court's decision is to articulate its standard of review — i.e., its benchmark for assessing the validity of the lower court's ruling. This requirement serves two functions: it informs the parties of the extent of the review and, most important, reminds the appellate court of the limitations placed on its own authority by the appellate procedure…. Awarding of the wrong standard of review may tilt the appellate playing field and irreparably prejudice a party's rights."13
As a event, a litigant increases the chance for success by clearly stating the standard and weaving it through each argument. To do so, a litigant must be able to correctly place the applicable standard of review.
• Conclusions of Law are Subject to De Novo Review —Conclusions of police force are field of study to the furthest-reaching standard of review for an appellate court, "de novo" review, which is a Latin expression that ways "of new" or "from the beginning," and expands the appellate courtroom's review of the issue as if information technology was seeing it for the beginning time. A question of law does not identify a trial court in a superior vantage bespeak, as the question does non turn on the evaluation of evidence.14 An appellate courtroom is equally as capable to return a determination on the question of law.
About commonly, de novo review applies in cases involving questions of law arising from undisputed facts because the legal effect presented by the bear witness is essentially a question of police force.15 A primary example is that Florida's appellate courts review a ruling on a motion to dismiss for failure to state a claim de novo.16 The ruling is limited to the four corners of the complaint and attachments, if whatever, and must assume all facts alleged in the complaint are truthful.17pattern, this type of motion tests the legal sufficiency of a claim, only does not decide issues of ultimate fact or whether the claim will prevail. A trial court will not grant such a motion in haste because it must decide that it cannot be said that the complaint states a crusade of action,xviii and Florida law favors liberal amendment of pleadings,19 so that controversies may exist decided on the merits.twenty
A few other obvious examples of bug to which de novo review applies are appellate problems pertaining to a trial courtroom's interpretation of a contract.21 This is considering the terms of the contract and application of the law remain the aforementioned, regardless of the facts or testify presented. For the same reason, de novo review applies to cases involving statutory interpretation,22 the grant of a dispositive motion such every bit motion for judgment as a matter of law or directed verdict, or motion for summary judgment,23 or governing a punitive damages amendment.24 In such instances, the focus of the research is whether there was a genuine or disputed event of fact and whether the trial court applied the correct rule of police, just does not require an actual resolution on the disputed issue of fact, if any.25 Evidentiary questions that do non require a factual inquiry may also be reviewed under this standard.26
De novo review presents a rare opportunity for an appellant to have a 2nd take chances at redemption on the precise issue raised below and is the most favorable standard for an appellant seeking reversal. An appellant should frame the ruling on appeal as a error of police force, which presents the path of least resistance for reversal.
Nevertheless, it strikes fear into the middle of an appellee who seeks an affirmance. An appellee should vigorously defend the trial court'due south ruling and consider whether a colorable argument to advocate for a more stringent standard of review exists.
• Findings of Fact are Reviewed for Competent, Substantial Bear witness —A trial court's findings of fact are cloaked in a presumption of correctness and reviewed for whether they are supported by competent substantial prove.27 A ruling will not be disturbed when in that location is record prove to permit a rational trier of fact to achieve the conclusion that was drawn. Considering the assignment of the weight given to the bear witness or credibility of the witnesses rests soundly within the province of the finder of fact, an appellate court does non decide whether to have or reject testify, as a matter of police force.28
An appellant will need to show that there is no credible evidence to support the complained-of factual finding, and must convince the courtroom that the findings lack any rational connection to the tape or that the weight of the bear witness renders a finding wrong. Such circumstances are rare. This lenient standard pays substantial deference to the lower court's ruling.29
• Mixed Conclusions of Police and Findings of Fact —Certain legal bug nowadays both a question of law and a question of fact. In such instances, an appellate court will review a ruling that involves a mixed question of police and fact under both de novo review and for competent substantial evidence or an abuse of discretion.thirty The trial courtroom's ruling on a question of law is subject area to de novo review. Meanwhile its ruling on a question of fact is reviewed for competent substantial evidence.
Problems pertaining to contract interpretation frequently involve mixed questions of law and fact. For example, a trial court's ruling on a motion to compel mediation presents mixed questions of law and fact.31 The trial court must resolve questions of fact equally to whether there is the existence of a valid arbitration understanding, an arbitrable issue, and whether the issue was waived.32 Yet, the ultimate ruling under this inquiry also necessarily involves the interpretation of a contract, which presents a matter of police.33 For the same reasons, review of a trial courtroom'due south ruling equally to an honour of attorneys' fees and costs is also subject field to this mixed standard.34
An appellee should either persuade the appellate court that the ruling is subject field to a more stringent standard of review, or, alternatively, demonstrate why the trial court'due south ruling on the matter of law was correct and rebut the existence or absence of evidence asserted past appellant.
• Discretionary Decisions Are Reviewed for an Abuse of Discretion —The abuse of discretion standard is the nigh deferential standard with respect to the trial court'due south ruling. "In reviewing a true discretionary act, the appellate court must fully recognize the superior vantage signal of the trial guess and should utilise the 'reasonableness' test to determine whether the trial judge driveling his discretion."35 This is an incredibly difficult standard to overcome, and the discretionary ruling of the trial guess should exist disturbed but when the determination fails to satisfy this test of reasonableness, which provides: "If reasonable men could differ every bit to the propriety of the action taken past the trial court, then the action is not unreasonable and there can exist no finding of an abuse of discretion."36 Nether this standard, a trial court'south ruling will be upheld unless the "judicial action is capricious, fanciful, or unreasonable …discretion is abused simply where no reasonable person would take the view adopted by the trial court."37
Discretionary decisions usually involve decisions regarding procedure, evidence, or equity, and resultantly, the corruption of discretion standard applies largely to procedural matters, rulings on the admissibility of evidence, and matters sounding in equity. Procedural vehicles for relief are reviewed under this standard. For case, when reviewing a trial court'southward grant of a new trial, an appellate court must recognize the broad discretionary authority of the trial approximate and apply the reasonableness examination to determine whether the trial judge committed an abuse of discretion.38 Orders awarding attorneys' fees as a sanction for raising frivolous claims or defenses are reviewed for an abuse of discretion.39 An appellate court will apply an abuse of discretion standard when information technology reviews a trial court ruling regarding jury pick40 or the admissibility of evidence.41
Appellate courts look at unlike circumstances, such as poor decision-making processes, consideration of factors that should not take been considered, or the failure to consider facts that should accept been considered,42 in determining whether a trial court driveling its discretion. Discretion by the trial approximate to decide a matter in a different manner than an appellate gauge is non plenty to demonstrate an abuse of discretion.43
This standard is the nearly difficult for an appellant to overcome. An appellant should carefully consider whether to raise issues subject to this standard or advocate for a different standard when appropriate. This standard is the most favorable for an appellee, and an appellee should be sure to highlight this standard.
Judicial Efficiency and Standards to Affirm in the Face of Error
Not all legal error is created equal. Florida's courts recognize that a political party is entitled to a fair trial but not a perfect ane.44 As such, an appellate court evaluates on a instance-past-example footing whether it should correct or decline to correct an error in the underlying proceedings.45 Even if it determines that the trial court erred in reaching a conclusion of law, finding of fact, or discretionary decision, if information technology concludes the error was harmless46 or the right result was reached, an appellate courtroom may yet assert the trial courtroom's erroneous ruling. The rationale is simple and centers on judicial efficiency: It would be inefficient and impractical to permit reversal in every case in which mistake can exist constitute. Nearly every case contains fault, so the law distinguishes between those errors that are "harmless47 and those that are harmful or reversible.
• Harmless Fault —In Florida, an appellate court may decline to correct legal fault and affirm a trial court's erroneous ruling when the error is harmless. Practitioners have often confused this standard because the statutory language and black-letter law articulate two differing iterations for the same test. Florida's legislature has the power to enact statutes, and as such, enacted Florida's harmless error statute. The statutory framework provides that "[n]o judgment shall be prepare aside or revered, or new trial granted by any court of the state in any cause…unless…after an examination of the entire case it shall appear that the fault complained of has resulted in a miscarriage of justice."48
However, the Florida Supreme Courtroom retains the "inherent authority to make up one's mind when an error is harmless and the analysis to be used in making the decision."49 The court has rejected the "miscarriage of justice" standard, and instead requires "the beneficiary of the error [has the burden] to prove beyond a reasonable dubiousness that the error complained of did non contribute to the verdict or, alternatively stated, that there is no reasonable possibility that the error contributed to the conviction."50 The Florida Supreme Court test prevails in both criminal and civil appeals and is the standard applied to decide whether an error is harmless.
From a applied standpoint, an appellate court will not waste limited judicial time and resources to opposite an erroneous trial court conclusion that did not contribute to the verdict. Harmless error makes it more difficult for an appellant to obtain a reversal, considering it acts as an additional filter. Merely stated, even if an appellant is able to demonstrate error in a trial courtroom ruling the appellant volition likely besides need to demonstrate that the error was not harmless. In contrast, an appellee volition desire to emphasize that whatsoever mistake was harmless.
• The Tipsy Coachman Doctrine —The Tipsy Coachman doctrine first appeared in the 1879 opinion of the Georgia Supreme Court in Lee five. Porter, 63 Ga. 345 (1879), which states that if the trial courtroom reaches the right consequence, but for the wrong reasons, it will exist upheld if there is any basis that would support the judgment in the record. Nearly eight decades later, Florida adopted this doctrine in Carraway five. Armour & Co., 156 So. second 494 (1963). The "central to the awarding of this doctrine of appellate efficiency is that there must have been back up for the alternative theory or principle of law in the record before the trial court."51 Thus, if a trial decision is right for the wrong reason, it may be affirmed on entreatment when the theory or legal principle is supported by the record.52
Conclusion
Litigators should familiarize themselves with the interplay between the categories of trial court rulings and standards of appellate review. The relationships between each serve every bit valuable guideposts when evaluating legal issues, preserving an event for entreatment and developing the tape, predicting a ruling, or framing an consequence on appeal. Effective practitioners are familiar with and contemplate which standard of review will apply to each legal result to maximize the potential for success.
1 This article serves every bit a primer for the everyday litigator on the nigh mutual appellate standards of review in ceremonious cases. Practitioners are duty bound to "disclose to a tribunal a legal authority in the decision-making jurisdiction known to the lawyer to exist straight agin to the position of the client and non disclosed past opposing counsel." Rule Reg. Fla. Bar 4-iii.3. Nothing in this article should be construed to suggest that whatsoever practitioner is absolved of that duty. Further, this article does non accost the different standards of review that may utilise to legal issues in criminal, family law, authoritative matters, or the tests practical to writ petitions in original jurisdiction proceedings.
2 Harvey J. Sepler, Appellate Standards of Review, Florida Appellate Practice CLE half dozen, 6.two (10th ed. 2017).
iii Certain technological advances beg the question whether standards of review may ane day change as new technological advances provide appellate courts with the ability to run across the testify from the aforementioned vantage point as the trial court.
four Run into Bruno five. State, 807 And then. 2d 55 (Fla. 2001); Metropolis of Coral Gables v. Country ex rel. Hassenteufel, 38 And so. 2d 467 (Fla. 1948); Pennsylvania Ins. Guar. Donkey'n five. Sikes, 590 So. 2d 1051 (Fla. 3d DCA 1991); run into also Philip J. Padavano, Florida Appellate Do 7:1 (2017 ed.).
v See Jacob five. Henderson, 840 So. 2d 1167 (Fla. 2d DCA 2003); Axelrod v. Dep't of Children and Family unit Servs., 799 So. 2d 1103 (Fla. 4th DCA 2001); Monroe v. Country, 191 So. 3d 395 (Fla. 2016).
half-dozen The Florida Supreme Court consists of 7 justices: 5 are required for a quorum and four are required for a bulk. Fla. Const. art. 5, §3(a). Each of the five district courts of appeal consist of at least iii judges and at least three judges are required to consider each case. Fla. Const. fine art. V, §4(a).
vii At that place are numerous standards of review, every bit well as iterations of each of those standards. Nonetheless, this commodity acts as a primer and discusses merely those that are the nigh mutual to provide a foundational understanding of the relationship between trial courtroom rulings and appellate standards of review.
8 The U.S. Supreme Court has recognized the "vexatious nature" of distinguishing betwixt a question of fact and question of law. Come across, e.g., Pullman-Standard v. Swint, 456 U.S. 273, 288 (1982); Baumgartner v. U.s., 322 U.S. 665, 671 (1944).
9 Encounter Parts & Elec. Motors, Inc. v. Sterling Elec., Inc., 866 F.2nd 228, 233 (7th Cir. 1988); Sierra Fria Corp. v. Donald J. Evans, P.C., 127 F.3d 175, 181 (1st Cir. 1997); Tolbert five. Page, 182 F.3d 677, 682 (ninth Cir. 1999).
10 Michael R. Fontham, et al., Persuasive Written and Oral Advancement 274 (2002). "Hiding the standard is a prescription for defeat, because the courtroom will surely observe and apply it."
xi This commodity does not address key mistake, which is an exception to the preservation requirement is rarely found in civil proceedings.
12 Practitioners should be mindful that Fla. R. App. P. 9.210(b)(five) expressly requires inclusion of the standard of review in appellate briefs.
thirteen North Fla. Women'southward Wellness & Counseling Servs., Inc. v. State, 866 So. 2d 612, 626 (Fla. 2003); see also Fla. R. App. P. 9.120(b)(5).
14 Florida Dept. of Revenue v. New Sea Escape Cruises, Ltd., 894 Then. second 954, 957 (Fla. 2005); Florida Power & Light Co. v. Hayes, 122 And then. 3d 408, 411 (Fla. 4th DCA 2013).
xv Town of Palm Beach v. Palm Embankment Cnty., 460 So. 2d 879 (Fla. 1984); Bradley five. Waldrop, 611 So. 2d 31 (Fla. 1st DCA 1992).
16 Bell v. Indian River Mem'l Hosp., 778 So. 2d 1030, 1032 (Fla. 4th DCA 2001).
17 United Auto Ins. Co. 5. Law Offices of Michael I. Libman, 46 So. 3d 1101, 1003 (Fla. 3d DCA 2010).
xviii Fla. R. Civ. P. 1.061 ("Orders granting or denying dismissal for forum not conveniens are subject field to…an abuse-of-discretion standard."); see likewise Kinney System, Inc. v. Continental Ins. Co., 674 And then. 2d 86 (Fla. 1996).
nineteen Rulings on the amendment of pleadings are field of study to an abuse of discretion standard. Run across Carib Ocean Shipping, Inc. 5. Armas 54 Then. 2d 234 (Fla. 3d DCA 2003).
20 See Fla. R. Civ. P. one.190.
21 Hayes, 122 And so. 3d 408, 411 (Fla. 4th DCA 2013); Reilly five. Reilly, 94 So. 3d 693, 697 (Fla. 4th DCA 2012).
22 New Bounding main Escape Cruises, Ltd., 894 So. 2d at 957.
23 Bell, 778 And then. 2d at 1032.
24 Varnedore v. Copeland, 210 So. 3d 741, 748 (Fla. 5th DCA 2017) (citing In Estate of Despain v. Avante Group, Inc., 900 So. 2d 637, 642-44 (Fla. fifth DCA 2005)).
25 Sepler, Appellate Standards of Review 6.iv (citing Moore five. Morris, 475 So. 2d 666 (Fla. 1985)).
26 Id. (citing Burkey v. Land, 922 Then. second 1033, 1035 (Fla. 4th DCA 2006)).
27 Sarasota Citizens for Responsible Gov't 5. Urban center of Sarasota, 48 So. 3d 755 (Fla. 2010); Liner v. Workers Temporary Staffing, Inc., 990 So. 2d 473 (Fla. 2008).
28 Evans v. Thornton, 898 So. 2d 151 (Fla. 4th DCA 2005); Southwin, Inc. v. Verde, 806 So. 2nd 586 (Fla. 3d DCA 2002).
29 Land Trust Realty, 207 So. 3d 923 (Fla. quaternary DCA 2016); City of Cocoa v. Leffler, 803 So. 2d 869 (Fla. 5th DCA 2002).
thirty Berlin v. Pecora, 968 So. 2d 47, l (Fla. quaternary DCA 2007) (quoting Jockey Club, Inc. v. Stern, 408 So. 2nd 854, 855 (Fla. 3d DCA 1982)).
31 Kendall Imports, LLC v. Diaz, 215 And then. 3d 95, 98-99 (Fla. 3d DCA 2017), reh'g den. (Mar. 30, 2017), review den., No. SC17-792, 2017 WL 4161247 (Fla. Sept. 20, 2017).
32 Id.
33 Id.
34 Webber for Keitel v. D'Agostino, No. 4D17-3007, 2018 WL 3301892, at *ane (Fla. 4th DCA 2018) (citing Klinow v. Island Courtroom at Boca Due west. Prop. Owners' Ass'n, Inc., 64 And so. 3d 177, 180 (Fla. fourth DCA 2011)).
35 Canakaris, 382 So. 2nd 1197, 1203 (Fla. 1980).
36 Id.
37 Trease five. Land, 768 And so. 2d 1050, 1053 northward.2 (Fla. 2000).
38 Brown five. Estate of Stuckey, 749 So. 2d 490, 497-98 (Fla. 1999).
39 Jean-Pierre v. Glaberman, 192 So. 2d 613, 613 (Fla. fourth DCA 2016) (quoting Lago v. Kame Design, LLC, 120 So. 3d 73, 74 (Fla. 4th DCA 2013)).
forty Schofield v. Carnival Prowl Lines, Inc., 461 Then. 2nd 152 (Fla. 3d DCA 1984); and Barrios v. Locastro, 166 So. 3d 863 (Fla. 4th DCA 2015), review den., 182 So. 3d 633 (Fla. 2015).
41 See Knight v. State, 15 So. 3d 936, 938 (Fla. 3d DCA 2009). A ruling on the admissibility of evidence is distinguishable from awarding of the evidence lawmaking — an alleged mistake in applying the rules of bear witness or on whether certain show constitutes hearsay will be reviewed de novo considering both are questions of law. Likewise, a decision to certify a course is subject to this standard because a determination of whether certification is appropriate typically involves multifactorial analysis that requires certain discretionary calls by the trial court. See Sosa five. Safeway Premium Finance Co., 73 So. 3d 91 (Fla. 2011) (certification does non involve the merits of the crusade of activity); Adiel five. Electronic Fiscal Systems, Inc., 513 Then. 2d 1347 (Fla. 3d DCA 1987); Morgan v. Coats, 33 Then. 3d 59 (Fla. 2d DCA 2010).
42 Steven Alan Childress & Martha S. Davis, ane Federal Standards of Review, notation 27, 4.01(3) at iv, 12-fifteen (4th ed. 2010).
43 Id.
44 U.S. v. Lutwak, 344 U.S. 604, 619 (1953); see generally Brunell 5. State, 456 And then. 2d 1324, 1324 (Fla. 4th DCA 1984); Vedder v. State, 313 So. 2d 49, 50 (Fla. 3d DCA 1975); Farnell five. State, 214 And then. 2d 753, 759 (Fla. 2d DCA 1968).
45 Special v. West Boca Medical Center, 160 So. 3d 1251, 1257 (Fla. 2014). "The test acts in a manner so as to conserve judicial resources while protecting the integrity of the process."
46 See Id. at 1256-57; State v. Diguilio, 491 And so. 2d 1129 (Fla. 1986).
47 Special, 160 So. 3d at 1251, 1256-57.
48 Fla. Stat. §59.041(accent added).
49 Goodwin v. State, 751 And so. 2d 537, 546 (Fla. 1999).
fifty Special, 160 Then. 3d at 1256 ("[T]his test is consequent with the harmless error rule codified in section 59.041 because it "focus[es] on the consequence of the error on the trier-of-fact," "strikes the proper rest betwixt the parties," and "strikes the appropriate balance betwixt the need for finality and the integrity of the judicial process."); see, due east.g., Diguilio, 491 So. 2d at 1135.
51 Robertson v. State, 829 And then. 2d 901, 906-907 (Fla. 2002).
52 James A. Herb & Jay L. Kauffman, Tales of the Tipsy Coachman: Being Right for the Wrong Reason — The Tipsy Coachman is Live and Well and Living in Florida, 81 Fla. Bar J. 36 (December. 2007).
RACHEL A. CANFIELD is a judicial law clerk for Gauge Thomas Logue of the Tertiary Commune Court of Appeal. She has practiced in Miami and served equally a judicial police clerk for Justice James E.C. Perry and judicial intern for Justice Jorge Labarga of the Florida Supreme Court. Peter Abraham, a student at St. Thomas University Schoolhouse of Constabulary, assisted with writing this article.
This cavalcade is submitted on behalf of the Appellate Practice Section, Sarah Lahlou-Amine, chair, and Thomas Seider, editor.
Source: https://www.floridabar.org/the-florida-bar-journal/raise-your-standards-a-practitioners-guide-to-the-effective-use-of-appellate-standards-of-review/
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