Background
Miguel Alvarez appealed a judgment of the County Court for Polk County in litigation against Lakeland Motors, LLC, doing business as Lakeland Chrysler. Lakeland Motors filed a cross-appeal. The short appellate opinion does not describe the parties’ underlying dispute or the county court’s ruling.
The record presented to the Sixth District Court of Appeal did not include the trial proceedings. Alvarez represented himself on appeal, while Lakeland Motors was represented by counsel.
The Court’s Holding
The Sixth District affirmed the county court’s judgment in a per curiam opinion. Judges Nardella, Mize, and Gannam concurred.
Citing Applegate v. Barnett Bank of Tallahassee, the court explained that without a record of the trial proceedings, an appellate court cannot properly resolve underlying factual issues or determine that the judgment lacks evidentiary support or support under an alternative theory.
Key Takeaways
- An appellant must provide a record sufficient to demonstrate reversible error.
- Without a record of the trial proceedings, an appellate court generally cannot reassess factual issues or the evidentiary basis for the judgment.
- The court affirmed without addressing the merits of the parties’ underlying dispute in its opinion.
Why It Matters
The decision underscores a basic appellate-practice requirement: the party seeking reversal bears responsibility for supplying the materials necessary to evaluate the claimed error. When the relevant trial record is absent, the appellate court will ordinarily presume the judgment is supported and affirm it.