Toms v. State — First DCA affirms in per curiam opinion without written reasoning

Case
Nathan Dale Toms v. State of Florida
Court
Florida First District Court of Appeal
Judge
LEWIS (Jeb Bush, 2001); Rowe (Charlie Crist, 2009)
Date Decided
June 12, 2026
Docket No.
1D2024-2989
Topics
Criminal appeal, Per curiam affirmance, Escambia County
Source
Read the full opinion

Background

Nathan Dale Toms appealed a judgment or order entered against him in the Circuit Court for Escambia County, Florida, before Judge John F. Simon, Jr. Toms was represented on appeal by the Office of the Public Defender for the Second Judicial Circuit, suggesting he is an indigent criminal defendant. The State of Florida, represented by the Office of the Attorney General, defended the lower court’s ruling.

The underlying facts, charges, and issues raised on appeal are not disclosed in the appellate decision. The First District Court of Appeal issued a per curiam affirmance without written opinion, which is a standard practice in Florida appellate courts when the panel unanimously finds no reversible error warranting elaboration.

The Court’s Holding

A three-judge panel consisting of Judges Lewis, Rowe, and Ray unanimously affirmed the lower court’s judgment. The court issued no written opinion explaining its reasoning, entering only the single word “AFFIRMED” as its disposition.

Because the court provided no written analysis, the specific legal issues considered and the grounds for affirmance are not discernible from the opinion itself. The decision is not yet final and remains subject to rehearing or clarification motions under Florida Rules of Appellate Procedure 9.330 and 9.331.

Key Takeaways

  • The First DCA affirmed the Escambia County circuit court’s ruling against Toms in all respects.
  • The per curiam affirmance carries no precedential value and contains no published legal analysis.
  • The decision is not yet final pending any timely motions for rehearing under Fla. R. App. P. 9.330 or 9.331.

Why It Matters

This case has no broad precedential significance, as per curiam affirmances without written opinion are not citable as authority in Florida courts. Its practical effect is limited to the parties: Toms’s conviction or sentence as entered by the Escambia County circuit court stands.

For practitioners, the case illustrates the First DCA’s routine use of unelaborated affirmances in criminal appeals where the panel finds no reversible error meriting discussion, a common disposition that conserves judicial resources while conclusively resolving the appeal for the parties involved.

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