Background
Sharrieff Corey Pope and Yoselyn Cardozo, proceeding without counsel, appealed a Miami-Dade County Court judgment involving DT Residential North, LLC and DT Residential South, LLC.
The appellate opinion does not describe the underlying dispute or the county court’s ruling in detail. It states that the appellants did not provide a record of the trial proceedings.
The Court’s Holding
The Third District Court of Appeal affirmed per curiam. Because the appellate record lacked the trial proceedings, the court could not assess factual challenges to the judgment or determine whether the trial court had misapplied the law.
The court relied on Applegate v. Barnett Bank of Tallahassee for the principle that an inadequate record prevents an appellant from demonstrating reversible error. It also cited decisions addressing waiver of evidentiary objections not raised at trial and the contemporaneous-objection rule.
Key Takeaways
- An appellant must provide a record adequate to demonstrate reversible error.
- Without a trial transcript or equivalent record, an appellate court generally cannot revisit factual issues or assess claimed trial error.
- Evidentiary objections ordinarily must be raised contemporaneously in the trial court to preserve them for appeal.
Why It Matters
The decision underscores that appellate review depends on a complete record. Even potentially meritorious challenges may fail when the appellant does not furnish the materials necessary to evaluate the claimed error.