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Diamond R. Fertilizer v. Hurt

Citations: 582 So. 2d 137; 1991 Fla. App. LEXIS 6550; 1991 WL 119684Docket: No. 91-1403

Court: District Court of Appeal of Florida; July 3, 1991; Florida; State Appellate Court

Narrative Opinion Summary

Diamond R. Fertilizer and Seibels Bruce Group petitioned for a writ of prohibition against the Judge of Compensation Claims (JCC), arguing that he should have disqualified himself due to a motion they filed. Although the JCC did not explicitly rule on the motion, he continued proceedings after its submission, which suggested he did not consider the motion valid. The court found that the motion for disqualification was timely and that the facts presented would lead a reasonable person to fear an impartial trial. It was noted that the JCC improperly evaluated the truth of the facts alleged in the motion. Consequently, the court granted the petition, ordering the JCC to disqualify himself from any further proceedings regarding the claim of respondent Davis against the petitioners. The decision was concurred by Judges Shivers, Wiggington, and Nimmons.

Legal Issues Addressed

Assessment of Alleged Facts in Disqualification Motions

Application: The JCC improperly assessed the truth of the facts alleged in the motion for disqualification rather than accepting them at face value, which influenced the court's decision to grant the petition.

Reasoning: It was noted that the JCC improperly evaluated the truth of the facts alleged in the motion.

Disqualification of Judge of Compensation Claims

Application: The court determined that the Judge of Compensation Claims (JCC) should disqualify himself from the proceedings due to a motion filed by the petitioners that raised valid concerns about impartiality.

Reasoning: Consequently, the court granted the petition, ordering the JCC to disqualify himself from any further proceedings regarding the claim of respondent Davis against the petitioners.

Timeliness of Motion for Disqualification

Application: The petitioners' motion for disqualification was deemed timely, implying the motion was filed within an appropriate period to address the concerns of impartiality before further proceedings.

Reasoning: The court found that the motion for disqualification was timely and that the facts presented would lead a reasonable person to fear an impartial trial.