Background
Malik Lewis appealed a final administrative child-support order issued by the Florida Department of Revenue, Child Support Program.
Lewis argued that his due-process rights were violated because he did not receive notice of a December 17, 2025 hearing conducted by the Department of Administrative Hearings.
The Court’s Holding
The Third District Court of Appeal affirmed per curiam. The record showed that, on September 29, 2025, the Department sent notice of the hearing to the address Lewis had provided to it, and the notice was not returned to the sender.
The court held that due process did not require proof that Lewis actually received the notice. Mailing the hearing notice to his address of record satisfied the government’s notice obligation in the administrative proceeding.
Key Takeaways
- An agency generally satisfies due process by sending notice to the affected party’s address of record.
- Actual receipt of mailed notice is not required when the government provides notice through a constitutionally adequate method.
- The court affirmed the final administrative child-support order.
Why It Matters
The decision reinforces that parties in administrative proceedings must keep their addresses current. A claim of nonreceipt will not establish a due-process violation where the record shows notice was mailed to the party’s supplied address and was not returned.