Hayes v. Hayes — Appeal dismissed as moot

Case
Michael Jason Hayes v. Jessica Ashley Hayes
Court
Florida First District Court of Appeal
Judge
Osterhaus, C.J.; Rowe, J.; Kelsey, J.
Date Decided
October 28, 2026
Docket No.
1D2026-0358
Topics
Mootness, Appellate Jurisdiction, Dismissal
Source
Read the full opinion

Background

Michael Jason Hayes appealed from a decision of the Circuit Court for Escambia County, where Judge Randall Todd Harris presided. Hayes represented himself on appeal, and no appearance was entered for Jessica Ashley Hayes.

The First District’s brief opinion does not describe the underlying claims, the challenged circuit-court ruling, or the circumstances that rendered the appeal moot.

The Court’s Holding

The Florida First District Court of Appeal dismissed the appeal as moot.

Citing Godwin v. State, 593 So. 2d 211, 212 (Fla. 1992), the court explained that an issue is moot when the controversy has been fully resolved such that a judicial decision can have no actual effect. The court provided no further analysis.

Key Takeaways

  • The First District dismissed the appeal because it was moot.
  • A controversy is moot when a judicial determination can no longer have an actual effect.
  • The opinion does not identify the underlying dispute or explain what made the controversy moot.

Why It Matters

The decision applies Florida’s settled mootness rule: an appellate court will not decide a controversy when its ruling can have no actual effect.

Because the per curiam opinion contains no factual discussion, its significance is limited to the dismissal and the general mootness principle it cites.

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