Background
Warren O. Crabb and Shashana Alford appealed from a decision of the Circuit Court for the Seventeenth Judicial Circuit in Broward County. Circuit Judge Michele Towbin Singer presided over the underlying case.
Crabb and Alford represented themselves on appeal, as did appellee Rita Neri. The Fourth District’s opinion does not describe the underlying dispute, the order being reviewed, or the appellants’ specific arguments.
The Court’s Holding
The Fourth District affirmed the circuit court’s decision in a per curiam opinion. The court cited Applegate v. Barnett Bank of Tallahassee, 377 So. 2d 1150 (Fla. 1979).
Applegate establishes that an appellant bears the burden of presenting a record sufficient to demonstrate reversible error and that, when the record is inadequate, an appellate court must presume the trial court’s decision was correct. The Fourth District provided no additional analysis of the appeal.
Key Takeaways
- The Fourth District affirmed the circuit court’s ruling without a written discussion of the underlying facts or issues.
- The citation to Applegate indicates that the appellants failed to provide a record sufficient to establish reversible error.
- Self-represented litigants, like represented parties, bear the burden of furnishing an adequate appellate record.
Why It Matters
The decision reinforces a fundamental appellate-practice requirement: arguments alone cannot establish trial-court error when the reviewing court lacks the materials needed to evaluate the challenged ruling. An incomplete record generally requires affirmance because the appellate court presumes the trial court acted correctly.