The decisions
- Florida Department of Law Enforcement v. Garcia (4th DCA, September 2, 2026) — Treats registry-removal petitions as civil regulatory proceedings appealable under rule 9.030(b)(1)(A), confirms FDLE's nonparty standing under section 943.0436(3), and expressly conflicts with the Second DCA's Korson. Read it →
- Department of Children and Families v. M.V. (6th DCA, September 30, 2026) — Holds courts cannot order an unserved, non-party DCF to take custody of a delinquency child outside section 985.115, and that prohibition bars contempt based on void orders. Read it →
- Village Center Community Development District v. Illeck (1st DCA, September 23, 2026) — Limits Harlem's 'heart disease' definition to arterial, valve, and blood-pressure conditions, so arrhythmias can qualify under section 112.18(1) when medical testimony, here unrebutted, establishes heart disease. Read it →
The practical upshot
- In registry-removal appeals, account for the Fourth/Second DCA split on jurisdiction, and for Garcia's rule that the statute version at petition filing governs.
- Agencies facing orders that impose duties beyond statutory authority should consider motions to vacate, certiorari, or prohibition, citing Garcia and M.V.
- In section 112.18 arrhythmia claims, develop or rebut IME testimony on whether the condition is heart disease rather than relying on Harlem's definition.
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