Laurence v. State
Twelve criminal defendants in Monroe County sought writs of prohibition to disqualify a trial judge whose spouse became Executive Director of the State Attorney's Office, an administrative (non-supervisory-over-attorneys) position. The Third District held the disqualification motions were legally insufficient because the spouse's role did not involve supervising or assisting in the prosecution of any case before the judge, adopting the reasoning of Florida JEAC Opinion 2023-09 and distinguishing Edwards v. State and its own prior decision in Brewer v. Hughes.
Key facts
- Twelve criminal defendants in Monroe County filed writs of prohibition seeking to disqualify a trial judge after the judge's spouse became Executive Director of the State Attorney's Office in an administrative, non-attorney-supervisory position.
- The defendants argued the spouse's employment in the State Attorney's Office created an objectively reasonable fear of bias, but the spouse did not supervise assistant state attorneys or participate in any cases before the judge.
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Why it matters
This opinion fills a gap the court itself acknowledges — there is 'very little case law' addressing when a judge must recuse because a spouse or immediate family member works for the prosecuting or defending agency… — full analysis with a trial
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