Background
E.D., the father of Em.D. and Ez.D., appealed a Miami-Dade County circuit court judgment terminating his parental rights. The circuit court proceeding was assigned lower tribunal number D24-15187.
The trial court found statutory grounds for termination under sections 39.806(1)(b) and 39.806(1)(f), Florida Statutes (2025). The appellate opinion does not detail the underlying conduct or evidence presented at trial.
The Court’s Holding
The Third District Court of Appeal affirmed the final judgment. It held that the record contained competent, substantial evidence supporting the Department of Children and Families’ proof, by clear and convincing evidence, that statutory grounds for termination existed under sections 39.806(1)(b) and (1)(f).
The court explained that termination based on egregious conduct is reviewed for competent, substantial evidence. It also emphasized that weighing evidence and making credibility determinations are functions of the trial court.
Key Takeaways
- The Third District upheld the termination of E.D.’s parental rights to both children.
- Competent, substantial evidence supported the trial court’s findings under sections 39.806(1)(b) and (1)(f).
- Appellate courts defer to the trial court’s weighing of evidence and credibility determinations.
Why It Matters
The decision reinforces the deferential appellate standard applied to factfinding in parental-rights termination cases. When the record contains competent, substantial evidence supporting statutory grounds proven by clear and convincing evidence, an appellate court will not reweigh the evidence or revisit the trial court’s credibility determinations.