Background
Debbie A. Crawford and Jeffrey L. Zurface appealed a nonfinal order entered in favor of Claim Specialists, Inc. by the Circuit Court for the Nineteenth Judicial Circuit in Indian River County.
The Fourth District’s brief per curiam opinion does not describe the underlying dispute, identify the nature of the nonfinal order, or set out the appellants’ arguments. It cites Applegate v. Barnett Bank of Tallahassee, 377 So. 2d 1150, 1152 (Fla. 1979), which addresses an appellant’s obligation to provide a record sufficient to demonstrate reversible error.
The Court’s Holding
The Fourth District affirmed the circuit court’s nonfinal order. The court provided no separate factual or legal analysis beyond its citation to Applegate.
That citation indicates the appellants did not present an appellate record sufficient to establish reversible error. When the record does not permit meaningful review of the claimed error, an appellate court must presume the trial court’s ruling was correct and affirm.
Key Takeaways
- An appellant bears the burden of supplying a record that demonstrates reversible error.
- An incomplete record can require affirmance even when the appeal concerns a nonfinal order.
- The opinion leaves the circuit court’s order in place without addressing the underlying dispute on its merits.
Why It Matters
The decision underscores that record preparation is outcome-determinative in Florida appellate practice. Parties challenging nonfinal orders must ensure the appellate record contains the materials needed to evaluate each claimed error.
Because the court issued only a citation affirmance, the decision provides no substantive guidance about the parties’ underlying claims or the particular order under review.