First District: Family Law, Delayed Rulings
This decision shows that a reversal can be built upon a lengthy delay in issuing a decision and an indication that something is “seriously amiss on the merits.”
The First District reversed a dissolution judgment entered more than a year after the trial court held an evidentiary hearing on the matter.
The district court identified “two key factors” in spotting something seriously amiss: inconsistency between the judge’s statements or findings at trial and the written order, and whether a factual finding is unsupported by the evidence.











