VINCENTE CARBAJAL - BRAVO
v.
STATE OF FLORIDA

Fla. 6th DCA | 2023-06-09
No. 2023-0392
Florida District Court of Appeal, Sixth District (2023)

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Synopsis

Vincente Carbajal Bravo appealed a trial court's order converting his motion for declaratory and injunctive relief into a mandamus petition and transferring it to Highlands County. The Florida District Court of Appeal, Sixth District, reversed the venue transfer while affirming the conversion of the motion, finding that mandamus petitions against state agencies must follow general venue rules including 'home venue privilege.'


Holding

The court reversed the transfer of venue to Highlands County but affirmed the conversion of the motion to a mandamus petition. The trial court erred by transferring the matter to Highlands County because mandamus petitions are subject to general venue rules, including 'home venue privilege,' which provides that venue against state agencies properly lies in the county where the agency maintains its principal headquarters.


Headnotes

[1] A trial court errs by transferring a mandamus petition to a county other than the one where the state agency or subdivision maintains its principal headquarters, absent w…

[2] A motion seeking an order requiring a Clerk of Court to provide copying and certification costs for judicial records may be treated as a petition for writ of mandamus.

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Key Quotes

“recognizing that mandamus petitions are subject to the general venue rules, including 'home venue privilege,' which provides that 'venue in civil actions brought against the state or one of its agencies or subdivisions, absent waiver or exception, properly lies in the county where the state, agency, or subdivision, maintains it principal headquarters'”

Establishes that mandamus petitions follow general venue rules and 'home venue privilege' applies to actions against state agencies

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Facts & Procedural History

Bravo sought an order requiring the Polk County Clerk of Court to provide copying and certification costs for judicial records from his criminal case.…

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Opinion of the Court

STARGEL, J.

Vincente Carbajal Bravo appeals the trial court's order converting his "Motion for Declaratory and Injunctive Relief" to a petition for writ of mandamus and transferring it to the civil division in Highlands County.1 Bravo's motion seeks an order requiring the Polk County Clerk of Court to provide copying and certification costs in connection with a request for judicial records from his criminal case. We reverse the transfer of venue but affirm the order in all other respects.2

NARDELLA and WHITE, JJ., concur. Vincente Carbajal Bravo, Avon Park, pro se.

Ashley Moody, Attorney General, Tallahassee, and Lydon W. Schultz, Assistant Attorney General, Tampa, for Appellee.

Footnotes
1 This case was transferred from the Second District Court of Appeal to this Court on January 1, 2023. 2 Bravo did not challenge any other finding or ruling in the order. concedes, the trial court erred by transferring the matter to Highlands County. See Bush v. State, 945 So. 2d 1207, 1212 (Fla. 2006) (recognizing that mandamus petitions are subject to the general venue rules, including "home venue privilege," which provides that "venue in civil actions brought against the state or one of its agencies or subdivisions, absent waiver or exception, properly lies in the county where the state, agency, or subdivision, maintains it principal headquarters" (quoting Carlile v. Game & Fresh Water Fish Comm'n, 354 So. 2d 362, 363-64 (Fla. 1977))). Accordingly, we reverse that portion of the trial court's order and remand for further proceedings consistent with this opinion.
2 As the State appropriately AFFIRMED in part, REVERSED in part, and REMANDED.

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