Publix Supermarkets, Inc. v. Jonida Goga, et al.
The Florida Supreme Court resolved a conflict among the district courts over the standard of review for a dismissal ordered as a sanction for fraud on the court, quashing the Fourth District's use of a specialized 'more stringent' or 'narrowed' abuse of discretion standard. The Court held that ordinary, component-specific standards apply: factual findings are reviewed for competent, substantial evidence, legal conclusions de novo, and the choice of sanction for abuse of discretion.
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