STATE OF FLORIDA
v.
RACHEL LYNN SCHARLEPP

Fla. 1st DCA | 2018-10-31
No. 18-1511
Ray, J., Osterhaus, J., Winokur, J.
255 So. 3d 995 Florida District Court of Appeal, First District (2018) Positive Treatment
Cited by 2 cases

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Synopsis

The Florida First District Court of Appeal granted the State's petition for a writ of prohibition to disqualify a trial judge who attempted to refute charges of partiality in denying the defendant's motion to disqualify, thereby exceeding the proper scope of judicial inquiry.


Holding

A trial judge must be disqualified when the judge attempts to refute charges of partiality rather than merely determining the legal sufficiency of a suggestion of prejudice.


Headnotes

[1] A trial judge exceeds the proper scope of judicial inquiry and establishes grounds for disqualification by attempting to refute charges of partiality rather than merely d…

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Key Quotes

“When a judge has looked beyond the mere legal sufficiency of a suggestion of prejudice and has attempted to refute the charges of partiality, he has then exceeded the proper scope of his inquiry and on that basis alone established grounds for his disqualification.”

Bundy v. Rudd, 366 So. 2d 440, 442 (Fla. 1978), establishing the controlling standard for judicial disqualification based on attempted refutation of partiality charges.

Facts & Procedural History

The State sought a writ of prohibition to disqualify the trial judge in a pending criminal matter against Rachel Lynn Scharlepp. The trial judge denie…

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Opinion of the Court

PER CURIAM.

The state seeks a writ of prohibition disqualifying the trial judge in a pending criminal matter. We agree that in denying the state’s second motion to disqualify, the trial judge attempted to refute the charges of partiality. This created an independent basis for disqualification. See Bundy v. Rudd, 366 So. 2d 440, 442 (Fla. 1978) (“When a judge has looked beyond the mere legal sufficiency of a suggestion of prejudice and has attempted to refute the charges of partiality, he has then exceeded the proper scope of his inquiry and on that basis alone established grounds for his disqualification.”); accord Lee Mem’l Health Sys. v. State, Agency for Health Care Admin., 910 So. 2d 892, 893 (Fla 1st DCA 2005); Martin v. State, 820 So. 2d 403, 404 (Fla. 3rd DCA 2002). We grant the petition but withhold formal issuance of the writ as we are confident the judge will promptly issue an order of disqualification.

RAY, OSTERHAUS, and WINOKUR, JJ., concur.

_____________________________

Not final until disposition of any timely and authorized motion under Fla. R. App. P. 9.330 or 9.331. _____________________________

Pamela Jo Bondi, Attorney General, and Jason W. Rodriguez, Assistant Attorney General, Tallahassee, for Petitioner.

Thomas M. Findley of Baker, Donelson, Bearman, Caldwell & Berkowitz, PC, Tallahassee, for Respondent.

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