INQUIRY CONCERNING A JUDGE JQC NO. 2025-1109 RE: J. LAYNE SMITH
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A judge who makes numerous intemperate and caustic comments evidencing bias against attorneys and parties during a hearing violates Canons 1, 2, 3B(4), 3B(5), and 3E(1) of the Code of Judicial Conduct and is subject to public reprimand.
[1] A judge's intemperate and caustic comments to attorneys and parties during a hearing, including statements expressing violent frustration and derogatory characterizations…
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Join FLexlaw to unlock all legal intelligence“I would like to tell the deputy to pull his gun and shoot all three of you as far as my level of frustration right now. I really don't want him to do that.”
Statement made by Judge Smith to the parties during the Order to Show Cause hearing on September 23, 2025.
Judge J. Layne Smith presided over a discovery motion hearing in Raker v. Vause on September 23, 2025, where he became frustrated with the attorneys' …
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Supreme Court of Florida
No. SC2026-0476
INQUIRY CONCERNING A JUDGE JQC NO. 2025-1109
RE: J. LAYNE SMITH.
September 24, 2026
PER CURIAM.
Before the Court are the Judicial Qualifications Commission's Findings and Recommendation of Discipline and an accompanying joint stipulation to resolve charges against Judge J. Layne Smith of the Second Judicial Circuit. As explained below, we accept the findings and will impose the recommended discipline of a public reprimand. See art. V, § 12(c)(1), Fla. Const. (authorizing the Court to accept, reject, or modify the Commission's recommendations and to order appropriate discipline).
Judge Smith admits that he made numerous statements that were not patient, dignified, or courteous and evidenced bias against the attorneys during his time presiding over the matter of Raker v. Vause (Wakulla County Case No. 2022-CA-90). Most of these comments came on September 23, 2025, during an Order to Show Cause hearing for a motion to compel discovery. Judge Smith became frustrated with the parties' attorneys after learning they could not confirm that a party had been properly served. Over the remainder of the hearing, Judge Smith made numerous intemperate and caustic comments to the attorneys and the parties. At one point, Judge Smith told the parties: “I would like to tell the deputy to pull his gun and shoot all three of you as far as my level of frustration right now. I really don't want him to do that.” Judge Smith also belittled the attorneys, referring to them as the "Keystone Cops” and the "Apple Dumpling Gang.”
On October 2, 2025, Judge Smith recused himself from the case on his own accord. Then, on October 21, 2025, Judge Smith self-reported his behavior, issued a public apology, and recused himself from any remaining cases involving the parties to that case.
The Commission and Judge Smith agree that his actions violated various Canons of the Code of Judicial Conduct. Canons 1 and 2 require judges to uphold the integrity of the judiciary and to avoid impropriety and the appearance of impropriety. Canon 3B(4) requires judges to be “patient, dignified, and courteous to litigants,
jurors, witnesses, lawyers, and others with whom the judge deals in an official capacity." Canon 3B(5) requires judges to “perform judicial duties without bias or prejudice.” Finally, Canon 3E(1) requires judges to disqualify themselves in proceedings where their "impartiality might reasonably be questioned,” including instances where "the judge has a personal bias or prejudice concerning a party or a party's lawyer." Judge Smith's factual admissions amply support the Commission's legal conclusions.
For discipline, the Commission and Judge Smith have asked us to impose a public reprimand. The Commission notes that Judge Smith has no prior disciplinary history and has been remorseful and cooperative throughout these proceedings. Additionally, Judge Smith has recused himself from all cases involving the lawyers in question and has proactively implemented procedures such as taking recesses and necessary adjournments when faced with contentious court proceedings. Although we accept the Commission's recommendation, we emphasize that Judge Smith's conduct fell far below the standard of professionalism that Florida judges owe to those who appear before them.
We order Judge Smith to appear before this Court for the administration of a public reprimand at a time to be established by the Clerk of this Court.
It is so ordered.
COURIEL, C.J., and LABARGA, MUÑIZ, GROSSHANS, FRANCIS, BARRIOS, and TANENBAUM, JJ., concur.