HL Prince 400 Holding — Fourth District affirmed the nonfinal order

Case
HL Prince 400 Holding, LLC v. Timothy James Monroe, Jr.
Court
Florida Fourth District Court of Appeal
Judge
MAY (Jeb Bush, 2001); Forst (Rick Scott, 2013)
Date Decided
July 22, 2026
Docket No.
4D2026-0446
Topics
Appellate Procedure; Nonfinal Orders; Adequacy of Record
Source
Read the full opinion

Background

HL Prince 400 Holding, LLC appealed a nonfinal order entered in litigation against Timothy James Monroe, Jr. in the Seventeenth Judicial Circuit in Broward County. Circuit Judge Keathan Briscoe Frink entered the order.

The Fourth District’s brief opinion does not describe the underlying dispute, identify the type of nonfinal order under review, or recount the parties’ arguments.

The Court’s Holding

In a per curiam decision, the Fourth District affirmed the nonfinal order. The court provided no factual analysis or independent explanation of its reasoning.

The court cited Applegate v. Barnett Bank of Tallahassee, 377 So. 2d 1150, 1152 (Fla. 1979), which concerns an appellant’s obligation to provide a record sufficient to demonstrate reversible error. The citation indicates that the record before the appellate court did not establish error warranting reversal.

Key Takeaways

  • The Fourth District affirmed the trial court’s nonfinal order.
  • An appellant bears the burden of presenting a record adequate to demonstrate reversible error.
  • The opinion does not disclose the underlying facts, the nature of the challenged order, or the specific deficiency in the appellate record.

Why It Matters

The decision underscores a basic appellate-practice rule: a reviewing court generally cannot reverse when the record supplied by the appellant does not permit it to evaluate the claimed error. Parties appealing nonfinal orders should ensure that the appellate record contains the materials necessary to support each argument for reversal.

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