Florida Standard of Review Hybrid Clear Error Abuse of Discretion
Enhance Your Standards: A Practitioner's Guide to the Effective Apply of Appellate Standards of Review
Litigants are often tempted to address the merits of a legal issue, without reference to the applicative appellate standard of review. Withal, litigators should first identify and alert the presiding court to the applicable standard of review because information technology defines the telescopic of the appellate court'due south research, the level of deference to be paid to the lower tribunal's ruling,i and controls the effect of the issue or entreatment.
Many litigators unknowingly lose basis earlier they have even filed their notice of appeal. Trial courts are well enlightened of the lens through which a ruling will be reviewed and their decisions are tailored to comply with the standard of review long before any entreatment is taken. An effective practitioner contemplates which standard of review will apply to each legal consequence in a instance because doing so helps 1) identify whether an issue is worth pursuing; 2) ensure that an consequence is preserved for entreatment; 3) predict the mode a trial courtroom will rule on the event; and 4) and shed light on how to persuasively frame the effect during each stage of litigation. Without a firm understanding of the standards of review, a litigant volition be difficult-pressed to succeed on a motion or properly develop the tape for success on appeal.
Categories of Trial Court Rulings
Constructive use of a standard of review is informed by the rationale behind the occasion that gave rise to the need for the standard. The standards are a judicial construct, designed to efficiently and judiciously identify and correct harmful legal error.
Essentially, all trial courtroom rulings autumn into 1 of three categories: one) conclusions of law; 2) findings of fact; and 3) discretionary decisions.2 Because trial court judges preside lone and discover the presentation of show, the law presumes that a trial court is in a better suited position to oversee instance management, weigh evidence, resolve factual disputes, and make credibility determinations in the cases over which they preside,3 but their decisions are not binding and do not have precedential effect over other courts or cases.
Conversely, an appellate court'due south primary tasks are to review the deportment of a lower tribunal for "harmful" or "reversible" legal error, interpret the police force, establish uniform precedent and ensure uniform application of the police throughout the state, and administer justice.four An appellate court does not reweigh testify, resolve factual disputes, or make credibility determinations because appellate judges do not have the benefit of observing the presentation of evidence at trial. Instead, they review the common cold, hard tape on entreatment, which more often than not consists of pleadings, court 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 estimate is more than limited than that of a trial court estimate. This limitation reduces the potential for fault and allows for appellate court decisions to have binding, precedential effect over lower courts.
The Human relationship Between Trial Court Rulings and Appellate Standards of Review
In that location are merely 3 categories of trial court rulings and just a handful of the most mutual standards of review that apply in ceremonious proceedings.7 Each category confers upon the trial court a lesser or higher degree of judgment. The level of deference paid by the appellate court is in straight proportion to the level of judgment conferred upon the trial court. Despite a body of well-settled law on each standard, the applicable standard is not always apparent or clear.viiiThere may be many iterations of simply i standard. It may be difficult to distinguish betwixt a question of law and a question of fact, or the nature of the trial court ruling may be mixed. Equally a result, there are times when it is advisable for the parties to disagree as to the applicable standard, or even one iteration of the standard, and to nowadays persuasive argument to the court as to why ane standard or another should use.9 To ignore an unfavorable standard will just crusade the political party to lose the opportunity to persuade the courtroom to apply a more than favorable standard, or to provide the courtroom with an analysis of the legal issue through the advisable lens.10
Every bit discussed more fully below, to successfully navigate through murky legal bug in which the standard is unclear, information technology is critically important that a litigant empathize the theory behind each category and standard to effectively identify and employ the correct standard.
The Nigh Common Appellate Standards of Review in Ceremonious Cases
In civil cases, an appellate issue may be reviewed nether one of the following most common appellate standards of review (or any combination thereof): 1) de novo; 2) competent, substantial prove; iii) abuse of discretion; 4) harmless error; or five) the Tipsy Coachman doctrine.11
Standards of review serve a number of of import functions. Aside from their analytical value, they accept practical value as well. Florida law requires that practitioners include in their appellate briefs "[a]rgument with regard to each consequence, with commendation to appropriate government, and including the applicable appellate standard of review."12 The Florida Supreme Courtroom has underscored the importance and function of the standards of review in appellate proceedings:
"An appellate courtroom'south starting time 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 of import, reminds the appellate court of the limitations placed on its ain authorization by the appellate process…. Awarding of the incorrect standard of review may tilt the appellate playing field and irreparably prejudice a party'due south rights."13
As a outcome, a litigant increases the take chances for success past conspicuously stating the standard and weaving it through each argument. To do and then, a litigant must exist able to correctly identify the applicable standard of review.
• Conclusions of Law are Subject field to De Novo Review —Conclusions of law are field of study to the furthest-reaching standard of review for an appellate court, "de novo" review, which is a Latin expression that means "of new" or "from the offset," and expands the appellate court's review of the issue as if information technology was seeing it for the first time. A question of law does non identify a trial court in a superior vantage bespeak, as the question does not turn on the evaluation of evidence.14 An appellate court is as as capable to render a decision on the question of law.
Most ordinarily, de novo review applies in cases involving questions of police arising from undisputed facts because the legal consequence presented by the show is essentially a question of law.15 A principal example is that Florida'south 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 any, 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 determine problems of ultimate fact or whether the claim volition prevail. A trial court will not grant such a motion in haste because it must determine that information technology cannot exist said that the complaint states a cause of action,18 and Florida law favors liberal amendment of pleadings,19 then that controversies may be decided on the claim.20
A few other obvious examples of problems to which de novo review applies are appellate problems pertaining to a trial court'south interpretation of a contract.21 This is because the terms of the contract and application of the police remain the same, regardless of the facts or bear witness presented. For the aforementioned reason, de novo review applies to cases involving statutory interpretation,22 the grant of a dispositive motility 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 subpoena.24 In such instances, the focus of the inquiry is whether there was a genuine or disputed issue of fact and whether the trial courtroom applied the correct rule of police, but does not require an bodily resolution on the disputed issue of fact, if any.25 Evidentiary questions that do not require a factual enquiry may too exist reviewed under this standard.26
De novo review presents a rare opportunity for an appellant to have a second gamble 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 entreatment equally a mistake of law, which presents the path of to the lowest degree resistance for reversal.
Yet, it strikes fright into the heart of an appellee who seeks an affirmance. An appellee should vigorously defend the trial court's 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 Evidence —A trial courtroom's findings of fact are cloaked in a presumption of correctness and reviewed for whether they are supported past competent substantial testify.27 A ruling volition non be disturbed when in that location is record evidence to permit a rational trier of fact to reach the conclusion that was drawn. Because the assignment of the weight given to the bear witness or brownie of the witnesses rests soundly within the province of the finder of fact, an appellate court does not decide whether to have or reject evidence, as a matter of law.28
An appellant will need to show that there is no credible evidence to back up the complained-of factual finding, and must convince the court that the findings lack any rational connection to the record or that the weight of the evidence renders a finding wrong. Such circumstances are rare. This lenient standard pays substantial deference to the lower court'due south ruling.29
• Mixed Conclusions of Law and Findings of Fact —Certain legal issues present 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 law and fact under both de novo review and for competent substantial evidence or an abuse of discretion.30 The trial courtroom'southward ruling on a question of constabulary is subject to de novo review. Meanwhile its ruling on a question of fact is reviewed for competent substantial evidence.
Issues pertaining to contract estimation often involve mixed questions of law and fact. For example, a trial court's ruling on a motion to compel mediation presents mixed questions of police force and fact.31 The trial court must resolve questions of fact equally to whether there is the existence of a valid arbitration agreement, an arbitrable issue, and whether the event was waived.32 Yet, the ultimate ruling nether this inquiry also necessarily involves the interpretation of a contract, which presents a matter of constabulary.33 For the same reasons, review of a trial court'due south ruling as to an award of attorneys' fees and costs is as well subject to this mixed standard.34
An appellee should either persuade the appellate court that the ruling is subject field to a more than stringent standard of review, or, alternatively, demonstrate why the trial court'southward ruling on the matter of law was right and rebut the existence or absence of evidence asserted by appellant.
• Discretionary Decisions Are Reviewed for an Abuse of Discretion —The abuse of discretion standard is the most deferential standard with respect to the trial court's ruling. "In reviewing a truthful discretionary act, the appellate courtroom must fully recognize the superior vantage point of the trial estimate and should utilise the 'reasonableness' test to determine whether the trial estimate abused his discretion."35 This is an incredibly hard standard to overcome, and the discretionary ruling of the trial approximate should be disturbed only when the decision fails to satisfy this test of reasonableness, which provides: "If reasonable men could differ as to the propriety of the action taken by the trial court, then the action is not unreasonable and there can be no finding of an abuse of discretion."36 Under this standard, a trial court'due south ruling will be upheld unless the "judicial action is arbitrary, fanciful, or unreasonable …discretion is driveling only where no reasonable person would accept the view adopted by the trial court."37
Discretionary decisions usually involve decisions regarding procedure, evidence, or equity, and resultantly, the abuse of discretion standard applies largely to procedural matters, rulings on the admissibility of evidence, and matters sounding in disinterestedness. Procedural vehicles for relief are reviewed under this standard. For instance, when reviewing a trial court'southward grant of a new trial, an appellate court must recognize the broad discretionary authority of the trial guess and apply the reasonableness examination to make up one's mind whether the trial judge committed an corruption of discretion.38 Orders application attorneys' fees as a sanction for raising frivolous claims or defenses are reviewed for an corruption of discretion.39 An appellate court volition employ an corruption of discretion standard when information technology reviews a trial court ruling regarding jury choice40 or the admissibility of prove.41
Appellate courts look at different circumstances, such as poor controlling processes, consideration of factors that should not take been considered, or the failure to consider facts that should have been considered,42 in determining whether a trial court driveling its discretion. Discretion by the trial guess to decide a matter in a different manner than an appellate judge is not enough to demonstrate an corruption of discretion.43
This standard is the nearly difficult for an appellant to overcome. An appellant should carefully consider whether to raise problems subject area to this standard or abet for a unlike 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 party is entitled to a off-white trial simply not a perfect 1.44 Equally such, an appellate court evaluates on a case-by-case footing whether it should correct or turn down to correct an fault in the underlying proceedings.45 Even if it determines that the trial courtroom erred in reaching a decision of police, finding of fact, or discretionary decision, if it concludes the error was harmless46 or the right result was reached, an appellate court may still assert the trial court'due south erroneous ruling. The rationale is simple and centers on judicial efficiency: It would be inefficient and impractical to allow reversal in every example in which fault tin be constitute. Near every case contains mistake, so the law distinguishes between those errors that are "harmless47 and those that are harmful or reversible.
• Harmless Mistake —In Florida, an appellate court may decline to correct legal mistake and affirm a trial court's erroneous ruling when the fault is harmless. Practitioners accept oft confused this standard because the statutory language and blackness-letter police clear ii differing iterations for the same exam. 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 set aside or revered, or new trial granted by whatever courtroom of the state in whatever cause…unless…after an test of the entire case it shall appear that the error complained of has resulted in a miscarriage of justice."48
Withal, the Florida Supreme Court retains the "inherent authority to decide when an error is harmless and the analysis to be used in making the determination."49 The court has rejected the "miscarriage of justice" standard, and instead requires "the beneficiary of the mistake [has the burden] to evidence across a reasonable doubt that the error complained of did not contribute to the verdict or, alternatively stated, that at that place is no reasonable possibility that the error contributed to the confidence."50 The Florida Supreme Court test prevails in both criminal and ceremonious appeals and is the standard applied to determine whether an error is harmless.
From a practical standpoint, an appellate courtroom volition not waste limited judicial fourth dimension and resources to reverse an erroneous trial court decision that did not contribute to the verdict. Harmless fault makes it more than difficult for an appellant to obtain a reversal, because information technology acts as an additional filter. Simply stated, even if an appellant is able to demonstrate error in a trial court ruling the appellant will probable also need to demonstrate that the error was not harmless. In contrast, an appellee will desire to emphasize that any error was harmless.
• The Tipsy Coachman Doctrine —The Tipsy Coachman doctrine beginning appeared in the 1879 opinion of the Georgia Supreme Courtroom in Lee v. Porter, 63 Ga. 345 (1879), which states that if the trial court reaches the right result, simply for the wrong reasons, it volition exist upheld if in that location is any ground that would support the judgment in the tape. Nearly eight decades later, Florida adopted this doctrine in Carraway v. Armour & Co., 156 And so. second 494 (1963). The "cardinal to the application of this doctrine of appellate efficiency is that in that location must have been support for the alternative theory or principle of police force in the record before the trial courtroom."51 Thus, if a trial decision is right for the wrong reason, information technology may exist affirmed on entreatment when the theory or legal principle is supported past the record.52
Determination
Litigators should familiarize themselves with the interplay between the categories of trial court rulings and standards of appellate review. The relationships betwixt each serve as valuable guideposts when evaluating legal issues, preserving an issue for appeal and developing the record, predicting a ruling, or framing an outcome on appeal. Effective practitioners are familiar with and contemplate which standard of review will employ to each legal result to maximize the potential for success.
1 This commodity serves as a primer for the everyday litigator on the virtually mutual appellate standards of review in ceremonious cases. Practitioners are duty bound to "disembalm to a tribunal a legal say-so in the decision-making jurisdiction known to the lawyer to be directly agin to the position of the client and not disclosed by opposing counsel." Rule Reg. Fla. Bar four-three.three. Naught in this article should be construed to suggest that whatever practitioner is absolved of that duty. Further, this commodity does non address the different standards of review that may apply to legal problems in criminal, family unit law, administrative matters, or the tests applied to writ petitions in original jurisdiction proceedings.
two Harvey J. Sepler, Appellate Standards of Review, Florida Appellate Do CLE 6, 6.ii (10th ed. 2017).
3 Certain technological advances beg the question whether standards of review may one twenty-four hours change as new technological advances provide appellate courts with the ability to meet the evidence from the same vantage signal as the trial court.
4 See Bruno 5. State, 807 So. 2nd 55 (Fla. 2001); City of Coral Gables v. State ex rel. Hassenteufel, 38 And so. second 467 (Fla. 1948); Pennsylvania Ins. Guar. Ass'n v. Sikes, 590 So. 2d 1051 (Fla. 3d DCA 1991); come across also Philip J. Padavano, Florida Appellate Practice vii:ane (2017 ed.).
5 Run across Jacob 5. Henderson, 840 So. 2d 1167 (Fla. 2d DCA 2003); Axelrod v. Dep't of Children and Family Servs., 799 And then. 2d 1103 (Fla. 4th DCA 2001); Monroe v. State, 191 So. 3d 395 (Fla. 2016).
6 The Florida Supreme Court consists of 7 justices: five are required for a quorum and four are required for a bulk. Fla. Const. art. V, §three(a). Each of the five district courts of appeal consist of at least three judges and at least iii judges are required to consider each case. Fla. Const. art. V, §iv(a).
7 In that location are numerous standards of review, likewise equally iterations of each of those standards. However, this article acts as a primer and discusses simply those that are the about common to provide a foundational understanding of the relationship between trial courtroom rulings and appellate standards of review.
eight The U.S. Supreme Courtroom has recognized the "vexatious nature" of distinguishing between a question of fact and question of law. See, eastward.thou., Pullman-Standard v. Swint, 456 U.S. 273, 288 (1982); Baumgartner v. United states, 322 U.S. 665, 671 (1944).
9 Meet Parts & Elec. Motors, Inc. five. Sterling Elec., Inc., 866 F.2d 228, 233 (7th Cir. 1988); Sierra Fria Corp. five. Donald J. Evans, P.C., 127 F.3d 175, 181 (1st Cir. 1997); Tolbert v. Page, 182 F.3d 677, 682 (ninth Cir. 1999).
10 Michael R. Fontham, et al., Persuasive Written and Oral Advocacy 274 (2002). "Hiding the standard is a prescription for defeat, because the courtroom will surely find and apply it."
11 This article does not address key mistake, which is an exception to the preservation requirement is rarely plant in civil proceedings.
12 Practitioners should be mindful that Fla. R. App. P. 9.210(b)(v) expressly requires inclusion of the standard of review in appellate briefs.
13 North Fla. Women's Health & Counseling Servs., Inc. v. Country, 866 So. 2nd 612, 626 (Fla. 2003); see likewise Fla. R. App. P. 9.120(b)(5).
14 Florida Dept. of Revenue v. New Sea Escape Cruises, Ltd., 894 Then. 2nd 954, 957 (Fla. 2005); Florida Power & Light Co. v. Hayes, 122 So. 3d 408, 411 (Fla. 4th DCA 2013).
xv Town of Palm Beach v. Palm Embankment Cnty., 460 And so. 2nd 879 (Fla. 1984); Bradley 5. Waldrop, 611 And so. 2d 31 (Fla. 1st DCA 1992).
xvi Bell v. Indian River Mem'fifty Hosp., 778 Then. 2d 1030, 1032 (Fla. fourth DCA 2001).
17 United Auto Ins. Co. v. Law Offices of Michael I. Libman, 46 So. 3d 1101, 1003 (Fla. 3d DCA 2010).
18 Fla. R. Civ. P. i.061 ("Orders granting or denying dismissal for forum non conveniens are subject to…an abuse-of-discretion standard."); see also Kinney Organisation, Inc. v. Continental Ins. Co., 674 And then. 2d 86 (Fla. 1996).
19 Rulings on the amendment of pleadings are field of study to an abuse of discretion standard. Run across Carib Ocean Shipping, Inc. v. Armas 54 So. 2d 234 (Fla. 3d DCA 2003).
20 See Fla. R. Civ. P. 1.190.
21 Hayes, 122 So. 3d 408, 411 (Fla. fourth DCA 2013); Reilly v. Reilly, 94 So. 3d 693, 697 (Fla. fourth DCA 2012).
22 New Sea Escape Cruises, Ltd., 894 And so. second at 957.
23 Bell, 778 So. 2d at 1032.
24 Varnedore v. Copeland, 210 So. 3d 741, 748 (Fla. 5th DCA 2017) (citing In Manor of Despain v. Avante Group, Inc., 900 So. 2d 637, 642-44 (Fla. 5th DCA 2005)).
25 Sepler, Appellate Standards of Review half dozen.iv (citing Moore v. Morris, 475 So. 2d 666 (Fla. 1985)).
26 Id. (citing Burkey 5. State, 922 So. 2d 1033, 1035 (Fla. 4th DCA 2006)).
27 Sarasota Citizens for Responsible Gov't five. City of Sarasota, 48 So. 3d 755 (Fla. 2010); Liner five. Workers Temporary Staffing, Inc., 990 So. second 473 (Fla. 2008).
28 Evans 5. Thornton, 898 So. 2d 151 (Fla. 4th DCA 2005); Southwin, Inc. v. Verde, 806 So. 2d 586 (Fla. 3d DCA 2002).
29 State Trust Realty, 207 And then. 3d 923 (Fla. 4th DCA 2016); Metropolis of Cocoa v. Leffler, 803 So. 2nd 869 (Fla. 5th DCA 2002).
30 Berlin v. Pecora, 968 So. 2nd 47, 50 (Fla. 4th DCA 2007) (quoting Jockey Social club, Inc. v. Stern, 408 So. 2d 854, 855 (Fla. 3d DCA 1982)).
31 Kendall Imports, LLC 5. Diaz, 215 So. 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 *1 (Fla. 4th DCA 2018) (citing Klinow v. Isle Court at Boca Westward. Prop. Owners' Donkey'northward, Inc., 64 So. 3d 177, 180 (Fla. 4th DCA 2011)).
35 Canakaris, 382 So. 2d 1197, 1203 (Fla. 1980).
36 Id.
37 Trease v. Land, 768 So. second 1050, 1053 n.ii (Fla. 2000).
38 Brown v. Manor of Stuckey, 749 So. 2d 490, 497-98 (Fla. 1999).
39 Jean-Pierre v. Glaberman, 192 So. 2d 613, 613 (Fla. 4th DCA 2016) (quoting Lago v. Kame Blueprint, LLC, 120 And then. 3d 73, 74 (Fla. 4th DCA 2013)).
forty Schofield v. Carnival Cruise Lines, Inc., 461 So. 2nd 152 (Fla. 3d DCA 1984); and Barrios five. Locastro, 166 So. 3d 863 (Fla. 4th DCA 2015), review den., 182 So. 3d 633 (Fla. 2015).
41 See Knight v. State, 15 Then. 3d 936, 938 (Fla. 3d DCA 2009). A ruling on the admissibility of show is distinguishable from application of the evidence lawmaking — an declared fault in applying the rules of prove or on whether certain testify constitutes hearsay will be reviewed de novo because both are questions of police force. Likewise, a decision to certify a class is subject to this standard considering a decision of whether certification is appropriate typically involves multifactorial analysis that requires certain discretionary calls by the trial court. See Sosa v. Safeway Premium Finance Co., 73 So. 3d 91 (Fla. 2011) (certification does not involve the merits of the crusade of action); Adiel v. Electronic Financial Systems, Inc., 513 So. 2nd 1347 (Fla. 3d DCA 1987); Morgan v. Coats, 33 And then. 3d 59 (Fla. 2nd DCA 2010).
42 Steven Alan Childress & Martha S. Davis, one Federal Standards of Review, note 27, 4.01(3) at 4, 12-15 (4th ed. 2010).
43 Id.
44 U.Due south. five. Lutwak, 344 U.Southward. 604, 619 (1953); see generally Brunell v. State, 456 So. 2d 1324, 1324 (Fla. quaternary DCA 1984); Vedder v. Land, 313 And so. 2d 49, 50 (Fla. 3d DCA 1975); Farnell 5. State, 214 And then. 2d 753, 759 (Fla. 2d DCA 1968).
45 Special 5. Due west Boca Medical Eye, 160 And then. 3d 1251, 1257 (Fla. 2014). "The test acts in a mode so equally to conserve judicial resources while protecting the integrity of the process."
46 See Id. at 1256-57; Country 5. Diguilio, 491 So. second 1129 (Fla. 1986).
47 Special, 160 So. 3d at 1251, 1256-57.
48 Fla. Stat. §59.041(emphasis added).
49 Goodwin v. State, 751 And then. 2d 537, 546 (Fla. 1999).
l Special, 160 Then. 3d at 1256 ("[T]his exam is consequent with the harmless error rule codified in section 59.041 because it "focus[es] on the outcome of the error on the trier-of-fact," "strikes the proper balance between the parties," and "strikes the appropriate balance between the demand for finality and the integrity of the judicial process."); see, e.g., Diguilio, 491 So. 2d at 1135.
51 Robertson five. State, 829 And then. 2d 901, 906-907 (Fla. 2002).
52 James A. Herb & Jay Fifty. Kauffman, Tales of the Tipsy Coachman: Existence Correct for the Wrong Reason — The Tipsy Coachman is Alive and Well and Living in Florida, 81 Fla. Bar J. 36 (Dec. 2007).
RACHEL A. CANFIELD is a judicial law clerk for Judge Thomas Logue of the Third District Court of Appeal. She has skilful in Miami and served as a judicial law clerk for Justice James E.C. Perry and judicial intern for Justice Jorge Labarga of the Florida Supreme Court. Peter Abraham, a educatee at St. Thomas Academy School of Constabulary, assisted with writing this article.
This column is submitted on behalf of the Appellate Exercise Department, 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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