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Inquiry Concerning a Judge, No. 09-518 re Colodny

Citations: 51 So. 3d 430; 35 Fla. L. Weekly Supp. 700; 2010 Fla. LEXIS 2055; 2010 WL 4878864Docket: No. SC10-1486

Court: Supreme Court of Florida; December 1, 2010; Florida; State Supreme Court

Narrative Opinion Summary

The case involves judicial misconduct by a circuit court judge during her 2008 campaign. The Judicial Qualifications Commission (JQC) charged the judge with misreporting $125,000 in campaign contributions as personal loans, violating section 106.08 of the Florida Statutes and several Canons of the Florida Code of Judicial Conduct. Although elected, she initially failed to disclose the true source of the loans and only corrected the disclosure following a JQC investigation. Acknowledging her actions as a misunderstanding of campaign finance laws, the judge cooperated with the investigation, correcting her filings and providing additional documentation. The JQC recommended a public reprimand and a $5,000 fine, citing the absence of intentional misrepresentation. The Florida Supreme Court, vested with the authority to determine judicial discipline under Article V, section 12 of the Florida Constitution, accepted the JQC's recommendation. It was noted that her misconduct was less severe than that of other judges who faced harsher penalties. The Court's decision reflects the mitigating factors, such as the judge's cooperation and lack of intent to deceive, distinguishing her case from more egregious violations.

Legal Issues Addressed

Comparison of Judicial Misconduct Severity

Application: The Court distinguished Judge Colodny's actions from more severe violations committed by other judges such as Judges Rodriguez and Pando, leading to a lesser penalty.

Reasoning: Judge Colodny's misconduct was less severe and more mitigated than that of Judges Rodriguez and Pando.

Judicial Discipline Under Article V, Section 12 of the Florida Constitution

Application: The Court retains ultimate authority to accept, reject, or modify JQC's disciplinary recommendations, approving a public reprimand and $5,000 fine for Judge Colodny.

Reasoning: Article V, section 12 of the Florida Constitution grants this Court the authority to accept, reject, or modify recommendations from the Judicial Qualifications Commission (JQC) regarding judicial misconduct.

Judicial Misconduct and Campaign Finance Violations

Application: Judge Colodny was found to have misreported campaign contributions as personal loans, violating Florida Statutes section 106.08 and breaching multiple Canons of the Florida Code of Judicial Conduct.

Reasoning: The JQC charged her with misreporting $125,000 in campaign contributions as loans from her when they were actually loans from her father, violating Florida Statutes section 106.08.

Mitigation in Judicial Discipline

Application: Judge Colodny's misconduct was mitigated by her cooperation and lack of intent to mislead, resulting in lesser disciplinary measures compared to other judges.

Reasoning: Judge Colodny accepted responsibility for her actions and admitted that the loan was intended for campaign purposes, claiming a misunderstanding of campaign finance laws.