Background
Aaron Michael Chin appealed from a proceeding before the Florida Department of Revenue, Child Support Program. The opinion does not describe the underlying child-support dispute or the agency ruling in detail.
Chin proceeded without counsel. The appellate record did not include a record of the trial proceedings.
The Court’s Holding
The Third District Court of Appeal affirmed per curiam. It held that, without a record of the proceedings below, the court could not resolve factual issues or determine whether the judgment lacked evidentiary support or rested on a legal error requiring reversal.
Relying on Applegate v. Barnett Bank of Tallahassee, the court applied the presumption that the lower tribunal’s decision was correct and concluded that Chin had not carried his burden to demonstrate reversible error.
Key Takeaways
- An appellant bears the burden to provide a record adequate to show reversible error.
- Absent a record of proceedings, an appellate court generally cannot reassess factual matters or the evidentiary basis for the ruling.
- The Department of Revenue child-support decision was affirmed.
Why It Matters
The decision illustrates the practical force of the record-on-appeal requirement. Even a potentially meritorious challenge may fail when the appellate court lacks the materials needed to evaluate the claimed error.