DETRIC I. BARRETT
v.
STATE OF FLORIDA DEPARTMENT OF REVENUE, CHILD SUPPORT PROGRAM, ET AL.

Fla. 3d DCA | 2026-02-11
No. 2025-1238
2026 FL 1494 Florida District Court of Appeal, Third District (2026)

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Holding

A party who waives the right to a hearing in a child support administrative proceeding waives the ability to challenge the sufficiency of the evidence supporting the agency's determination on appeal.


Key Quotes

“[B]y waiving his right to a hearing, Appellant waived his ability to challenge the sufficiency of the evidence to support the Department's determination of his child support obligations”

Standard v. State, Dep't of Revenue, Child Support Enf't Program, 249 So. 3d 798, 798–99 (Fla. 1st DCA 2018)

Facts & Procedural History

Detric I. Barrett challenged a child support determination made by the Florida Department of Revenue, Child Support Program. Barrett had waived his ri…

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Opinion of the Court

PER CURIAM.

Affirmed. See Standard v. State, Dep't of Revenue, Child Support Enf't Program, 249 So. 3d 798, 798–99 (Fla. 1st DCA 2018) (holding that "[b]y waiving his right to a hearing, Appellant waived his ability to challenge the sufficiency of the evidence to support the Department's determination of his child support obligations"); Feliciano v. Dep't of Revenue, Child Support Enf't, 305 So. 3d 801, 803 (Fla. 4th DCA 2020) (“Appellant's arguments on appeal are arguments that should have been presented and analyzed at a hearing."); see also City of Lake Wales v. Pub. Emp. Relations Comm’n, 402 So. 2d 1224, 1224-25 (Fla. 2d DCA 1981) (affirming two final administrative orders when “substantial, competent evidence support[ed] the findings of fact").


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