Lewis v. Florida Department of Revenue — child-support order affirmed after notice was mailed to his address of record

Case
Malik Lewis v. State of Florida Department of Revenue, Child Support Program, et al.
Court
Florida Third District Court of Appeal
Judge
Scales, C.J.; Logue; Gooden, JJ.
Date Decided
October 7, 2026
Docket No.
3D26-0105
Topics
Child support; Administrative law; Due process; Notice
Source
Read the full opinion

Background

Malik Lewis appealed a final administrative child-support order issued by the Florida Department of Revenue, Child Support Program.

Lewis argued that his due-process rights were violated because he did not receive notice of a December 17, 2025 hearing conducted by the Department of Administrative Hearings.

The Court’s Holding

The Third District Court of Appeal affirmed per curiam. The record showed that, on September 29, 2025, the Department sent notice of the hearing to the address Lewis had provided to it, and the notice was not returned to the sender.

The court held that due process did not require proof that Lewis actually received the notice. Mailing the hearing notice to his address of record satisfied the government’s notice obligation in the administrative proceeding.

Key Takeaways

  • An agency generally satisfies due process by sending notice to the affected party’s address of record.
  • Actual receipt of mailed notice is not required when the government provides notice through a constitutionally adequate method.
  • The court affirmed the final administrative child-support order.

Why It Matters

The decision reinforces that parties in administrative proceedings must keep their addresses current. A claim of nonreceipt will not establish a due-process violation where the record shows notice was mailed to the party’s supplied address and was not returned.

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