Haines City Community Dev. v. Heggs
658 So.2d 523, 1995 WL 392859 (1995)
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Rule of Law:
When a Florida district court of appeal reviews a circuit court's judgment acting in its appellate capacity, the standard of review is limited to whether the circuit court afforded procedural due process and applied the correct law. This standard is synonymous with determining whether there has been a departure from the essential requirements of law resulting in a miscarriage of justice.
Facts:
- Leila Heggs was a tenant in a property managed by Haines City Community Development, d/b/a Parkview Village (Parkview).
- A dispute arose between Heggs and Parkview concerning Heggs's alleged non-payment of rent.
- As a result of the rent dispute, Parkview initiated legal proceedings to evict Heggs from the property.
Procedural Posture:
- Haines City Community Development (Parkview) filed an eviction action against Leila Heggs in county court.
- The county court entered a final judgment in favor of Parkview, ordering the eviction of Heggs.
- Heggs, as appellant, appealed the county court's judgment to the circuit court.
- The circuit court, acting in its appellate capacity, reversed the county court's judgment.
- Parkview, as petitioner, then sought a writ of common-law certiorari from the Second District Court of Appeal to review the circuit court's appellate order.
- The district court denied the petition for certiorari but certified a question of great public importance to the Supreme Court of Florida.
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Issue:
Does the standard of review articulated in Combs v. State for district court certiorari review of a circuit court's appellate decision over a county court remain the governing standard after the decision in Education Development Center, Inc. v. City of West Palm Beach?
Opinions:
Majority - Justice Anstead
Yes. The standard of review in Combs still governs, as it is substantively the same as the standard articulated in Education Development Center (EDC). When a district court reviews a circuit court acting in its appellate capacity, the scope of review is limited to determining whether the circuit court afforded procedural due process and applied the correct law. The court's reasoning is that the phrase 'applied the correct law' from the EDC standard is synonymous with 'observing the essential requirements of law' from the Combs standard. Both standards prohibit the district court from reweighing evidence or conducting a second appeal. Instead, this narrow certiorari review is reserved for situations where the lower court has violated a 'clearly established principle of law resulting in a miscarriage of justice.' The court clarified that as a case moves up the judicial ladder, the scope of review should narrow, not broaden, reinforcing the finality of the circuit court's appellate role.
Analysis:
This decision harmonizes and clarifies the standard for second-tier certiorari review in Florida's district courts of appeal. By holding that the standards from Combs (cases originating in county courts) and Education Development Center (cases originating in administrative agencies) are the same, the Court created a uniform and narrow standard of review. This reinforces the principle that certiorari is not a second appeal and strengthens the finality of circuit court appellate decisions. The ruling ensures that district courts will only intervene to correct fundamental legal errors that constitute a miscarriage of justice, rather than re-evaluating the merits or evidence of a case that has already had one full appeal.
