In Re Guardianship of Schiavo

District Court of Appeal of Florida
916 So. 2d 814 (2005)

ELI5:

Rule of Law:

Under Florida Rule of Civil Procedure 1.540(b)(4), a final judgment is not void unless the court that entered it lacked subject matter jurisdiction or personal jurisdiction. Arguments concerning errors in the court's application of substantive law, even on constitutional grounds, do not render a judgment void and must be raised on direct appeal.

Facts:

In February 1990, Theresa Marie Schiavo suffered a heart attack that resulted in severe brain damage, leaving her in a persistent vegetative state.
She required a feeding tube to receive nutrition and hydration to remain alive.
Schiavo had not executed a living will or any other advance directive expressing her wishes regarding end-of-life care.
Her husband and legal guardian, Michael Schiavo, contended that she would not have wanted to be kept alive in her condition.
Schiavo's parents, Robert and Mary Schindler, disputed their son-in-law's claim and believed their daughter should be kept alive.
The conflict between Michael Schiavo and the Schindlers over Theresa's care led to a legal dispute to determine her wishes.

Procedural Posture:

Michael Schiavo, as guardian, petitioned the Florida trial court (a Circuit Court) to authorize the removal of Theresa Schiavo's feeding tube.
In February 2000, after a trial, the court found clear and convincing evidence that Theresa would have chosen to discontinue life-prolonging procedures and entered a judgment authorizing the removal.
Her parents, the Schindlers, appealed to the Florida Second District Court of Appeal, which affirmed the judgment.
The Schindlers filed subsequent motions for relief from judgment, which were also denied by the trial court and those denials were affirmed on appeal.
After the legislature passed a law allowing the governor to intervene, which was later found unconstitutional by the Florida Supreme Court, the Schindlers filed a new motion in the trial court to have the original 2000 judgment declared void under Rule 1.540(b)(4).
The trial court denied this motion to declare the judgment void.
The Schindlers, as appellants, appealed the trial court's denial to the Florida Second District Court of Appeal. Michael Schiavo is the appellee.

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Issue:

Is a final judgment ordering the withdrawal of life-prolonging procedures void under Florida Rule of Civil Procedure 1.540(b)(4) on the grounds that the court, rather than a guardian, determined the incapacitated person's wishes based on clear and convincing evidence?

Opinions:

Majority - Altenbernd, Chief Judge

No. A final judgment is not void simply because a party disagrees with the court's legal conclusions, which have already been affirmed on appeal. The trial court's authority to make a substituted judgment for an incapacitated person is well-established under Florida's constitutional right to privacy, and a motion to vacate a judgment as void is limited strictly to challenges of the court's fundamental jurisdiction. In this case, the trial court had proper jurisdiction over both the subject matter of the guardianship and the parties involved since 1990. The Schindlers' arguments regarding due process and the propriety of the court making the decision are substantive legal issues that were previously litigated and decided against them in prior appeals; they cannot be relitigated under the guise of a motion claiming the judgment is void.

Analysis:

This opinion reinforces the principle of finality in litigation, strictly limiting the grounds for vacating a judgment as void to fundamental jurisdictional defects. It prevents parties from using post-judgment motions to relitigate substantive legal issues that were, or could have been, raised on direct appeal. The decision solidifies the legal framework in Florida for end-of-life decisions, affirming that in the absence of an advance directive and amidst family disagreement, a court may serve as a surrogate to determine an incapacitated person's wishes based on a clear and convincing evidence standard. This provides legal certainty for profoundly difficult guardianship cases involving the constitutional right to refuse medical treatment.

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