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FL Supreme CourtOctober 15, 2026Referee's report disapproved; Respondent found guilty of violating Rules 4-3.3(a)(1) and 4-3.4(c); remanded to a new referee for discipline determination⭐ Notable

The Florida Bar v. Studstill

Case No. SC2024-0149

The Florida Supreme Court rejected a referee's recommendation of not guilty and found an attorney guilty of violating Rules 4-3.3(a)(1) (candor) and 4-3.4(c) (fairness/disobeying tribunal obligations) after he spoke with his own expert witness about excluded exhibits in contravention of the trial judge's express instruction that the witness have no contact with any party or party representative, and then misrepresented the conversation to the judge. The Court held the referee erred by focusing on the lawyer's motive rather than whether he acted knowingly, and that his COVID-related claims of impairment were not supported by competent, substantial evidence. A partial dissent argued the rule of sequestration under section 90.616 does not bar attorney-witness communications and that no special 'ruling' was ever entered.

Key facts

  • Attorney Studstill communicated with his own expert witness about excluded exhibits after the trial judge expressly instructed that the witness have no contact with any party or party representative until recalled.
  • Studstill then misrepresented the substance of that conversation to the trial judge.
  • +2 more key facts with a free trial

Why it matters

Although a Bar discipline case, the opinion gives civil trial lawyers a practical rule on sequestration orders: when a judge's oral instruction sweeps more broadly than section 90.616 (e.g., barring all contact with any… — full analysis with a trial

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