RICARDO MARRERO CARVAJAL
v.
STATE OF FLORIDA DEPARTMENT OF REVENUE, CHILD SUPPORT PROGRAM, ET AL.

Fla. 3d DCA | 2026-02-18
No. 2025-0662
Florida District Court of Appeal, Third District (2026)

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Holding

A party who fails to request an administrative hearing and does not fully participate in child support proceedings before the Department of Revenue cannot obtain appellate relief based on insufficient evidence when no transcript exists for review.


Key Quotes

“Although Appellant provided his financial information, he did not request an administrative hearing and therefore failed to fully participate in the proceedings below. . . . We note that the lack of a hearing and the resulting absence of a transcript provides this Court with little basis to conclude that the Department's final order is not supported by the evidence.”

Court's reasoning for affirming the Department's order despite insufficient record for review

Facts & Procedural History

Ricardo Marrero Carvajal appealed a child support order issued by the Florida Department of Revenue's Child Support Program. Although Carvajal provide…

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Opinion of the Court

PER CURIAM. Affirmed. Feliciano v. Dep't of Revenue, Child Support Enf't, 305 So. 3d 801, 803 (Fla. 4th DCA 2020) (“Here, although Appellant provided his financial information, he did not request an administrative hearing and therefore failed to fully participate in the proceedings below. . . . We note that the lack of a hearing and the resulting absence of a transcript provides this Court with little basis to conclude that the Department's final order is not supported by the evidence.").


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