Legal Memorandum: Reversal of Judgment in FL

Issue: What deference does the appellate court accord a bench trial decision in Florida?

When the trial judge sits as trier of fact, his judgment “comes to an appellate court clothed with a presumption of correctness.”  Hill v. Parks, 373 So. 2d 376, 377 (Fla. 2d Dist. Ct. App. 1979).  The court’s judgment may be reversed only when either (1) it is clear that the trial judge misapplied the law to the facts; or (2) the ruling is against the manifest weight of the evidence.  Id. at 377; see Becklin v. Travelers Indem. Co., 263 So. 2d 629, 631 (Fla. 1st Dist. Ct. App. 1972); Roe v. Macy, 363 So. 2d 616, 617 (Fla. 1st Dist. Ct. App. 1978).

When defendants fail to demonstrate that either of the above circumstances exists, the decision still must be affirmed if it is clearly correct for alternative or additional reasons.  “[I]f a trial court reaches the right result, but for the wrong reasons, it will be upheld if there is any basis which would support the judgment in the record.”  Dade County Sch. Bd. v. Radio Station WQBA, 731 So. 2d 638, 644 (Fla. 1999).

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