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10 Florida opinions name it 2 courts 2002–2025 1 in the last five years
The cases below were cited by Florida courts in a sentence that names this issue. Sides come from how each citing opinion treated the case (Syfertize flag on that citation), so a case can appear on both: that is where the law is contested. A red or yellow chip is the case's own overall treatment.
| Case | Followed | Cited |
|---|---|---|
Robertson v. Stategreen2 sentences2025See Robertson v. State, 829 So. 2d 901 , 906—07 (Fla. 2002) (“The key to the application of this doctrine of appellate efficiency is that there must have been support for the alternative theory or principle of law in the record before the trial court.”). 2019Cf. Robertson v. State, 829 So. 2d 901, 906-07 (Fla. 2002) ("The key to the application of [the tipsy coachman] doctrine of appellate efficiency is that there must have been support for the alternative theory or principle of law in the record before the trial court."). | 7 | 9 |
| Case | Negative | Cited |
|---|---|---|
| No negative-treatment citations attached to this issue in Florida. Read the followed side critically anyway. | ||
| Case | Cited | Years |
|---|---|---|
Dade Cty. Sch. Bd. v. Radio Station WQBA
green
1 sentence2013The Florida Supreme Court in Robertson italicized the phrase “in the record” from Radio Station WQBA to emphasize that an appellee may invoke the tipsy coachman doctrine if its legal arguments are supported by the record. 731 So.2d at 645 ; see Robertson, 829 So.2d at 906-07 (“The key to the application of this doctrine of appellate efficiency is that there must have been support for the alternative theory or principle of law in the record before the trial court.”); see also Padova-no, Florida Appellate Practice 343 (2011 ed.) (the “record must support the alternative theory that would be used | 1 | 2013–2013 |
State Farm Fire and Cas. Co. v. Levine
green
1 sentence2003Co. v. Levine, 837 So.2d 363 (Fla.2002). | 1 | 2003–2003 |
State, Dept. of Revenue Ex Rel. Rochell v. Morris
green
1 sentence2002Thus, following Radio Station WQBA , the First District in Morris, 736 So.2d at 42 , correctly refused to affirm on an alternative ground not argued to the trial court, reasoning that "the record does not reflect an evidentiary basis sufficient to permit us to make a determination as to whether these defenses are applicable in the instant case." (Emphasis supplied.) In the present case, the Third District improperly affirmed the admission of Robertson's ex-wife's testimony on the alternative Williams rule ground because there was no evidence in the record to support the Third District's holdin | 1 | 2002–2002 |