Kenneth Lindsey Mayfield v. State of Florida
While the panel summarily affirmed, Judge Lott's concurrence provides an extended scholarly examination of the per curiam affirmance and proposes that Florida adopt a selective-publication system—as in the federal courts and many states—that would let panels issue short non-precedential opinions explaining their reasoning while preserving the PCA. The concurrence reviews the precedential rules (Pardo, rule 9.040(i)) and the institutional debate over PCAs.
Key facts
- The Fourth District summarily affirmed a county-court misdemeanor judgment by per curiam affirmance (PCA) without written opinion.
- The appellant had complained that a PCA 'can give the impression that this Court does not care about the issues presented.'
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Holdings
- A per curiam affirmance without written opinion has no precedential value and binds only the parties through res judicata and law-of-the-case; under Pardo v. State and Fla. R. App. P…
Why it matters
Although the underlying disposition is a routine criminal PCA, Judge Lott's concurrence is a notable practitioner-facing treatment of Florida appellate procedure—cataloguing the case law and commentary on the… — full analysis with a trial
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