Angela Adriana Ramirez v. Haul Junkies LLC
After a nonjury trial resulted in involuntary dismissal with prejudice, the pro se appellant challenged the ruling on multiple grounds but failed to include a trial transcript in the appellate record. Applying the long-settled Applegate rule, the Third DCA affirmed because without a transcript an appellate court cannot evaluate whether the evidence supported the judgment or whether the trial court misapplied the law.
Key facts
- Following a nonjury trial in Miami-Dade County Court (small claims division, lower tribunal no. 25-5300-SP-05), the trial court involuntarily dismissed the case with prejudice.
- Pro se appellant Angela Adriana Ramirez appealed the dismissal, raising various challenges to the trial court's ruling.
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Holdings
- An appellant must provide a trial transcript to demonstrate reversible error; without it, the appellate court is constrained to affirm the trial court's judgment. Applegate v. Barnett Bank…
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