Hong Chen Lai v. Ruowen Shen
The Third District affirmed a small-claims judgment against a landlord who brought no transcript and no approved statement of evidence to the appeal. The court held that calling the issues 'pure questions of law' does not get around the record requirement when the arguments depend on how disputed trial evidence should be interpreted. Without a record, the appellant cannot overcome the presumption that the trial court's findings are correct, so a judgment that is not fundamentally erroneous on its face must be affirmed.
Key facts
- A landlord appealed a small-claims damages judgment entered after a non-jury trial in a landlord-tenant dispute in Miami-Dade County Court.
- The landlord filed no trial transcript, and the trial court never approved his proposed Statement of Evidence under Rule 9.200.
- +2 more key facts with a free trial
Holdings
- The appellant must overcome the presumption that the trial court's findings of fact are correct by showing they are not supported by competent substantial evidence. That burden cannot be…
- +1 more holding with a free trial
Why it matters
This is a short but useful reminder for practitioners, especially in county court and bench-trial appeals, that an appeal is only as good as its record. If the trial was not transcribed, counsel must get a statement of… — full analysis with a trial
🔒 Read the full opinion, holding & search the library
The full opinion PDF, the rules the court applied, our significance analysis, the background facts, and full-text search across every tracked Florida decision are available to members. Start a free 30-day trial — no credit card.
Not ready to sign up? Get the free Friday digest — the week's key Florida decisions by email, no login required.
Florida Court Tracker provides summaries of publicly available court opinions for informational and research purposes only. This is not legal advice and does not create an attorney–client relationship. Always verify holdings against the official opinion.