RUTH KING n/k/a RUTH MUNIZ v. MASHAWN KING, 22-1493

Muniz (mother) and King (father) litigated dissolution proceedings; the final judgment reserved jurisdiction over child support and related issues.
Muniz moved for child support determination, retroactive support, and a superseding child support order; an evidentiary hearing was held but no transcript was produced.
After the hearing, the trial court asked the parties to submit proposed orders; the court ultimately signed an order that matched King’s proposed order verbatim (except for date and removal of blanks), including typographical errors and conflicting paragraphs.
The court signed the order one business day after receiving King’s proposed order; the record does not show Muniz had an opportunity to review or object to King’s submission.
The Fourth District found the circumstances created the appearance the trial court did not exercise independent decision-making and reversed and remanded for further proceedings.

Issue	Muniz's Argument	King’s Argument	Held
Whether adopting a party’s proposed order verbatim without on-record findings is reversible	Adoption created appearance court didn’t independently decide; reversible error	Adoption permissible if reflects judge’s decision; not reversible per se	Reversed: appearance of lack of independent decision-making warranted remand
Whether absence of a hearing transcript precludes reversal	Lack of transcript shouldn’t bar review where record shows possible error	A transcript is necessary to show judge’s rulings; without it reversal improper	Transcript absence does not preclude reversal when record shows appearance of non-independent decision-making
Whether any errors were harmless because Muniz’s requests lacked merit	Substantive merits can’t be assessed without hearing transcript; cannot assume harmlessness	Claims were meritless; any adoption was harmless	Court declined to find harmless error without transcript and record to assess merits
Whether parties stipulated to all issues except support deviation	Muniz contends many issues remained contested	King contends parties stipulated except for upward deviation	Court found proposed orders showed disputes remained; stipulation claim unpersuasive

Perlow v. Berg-Perlow, 875 So. 2d 383 (Fla. 2004) (procedure and guidance when trial court requests and adopts proposed final judgments)
Ross v. Botha, 867 So. 2d 567 (Fla. 4th DCA 2004) (reversal where trial court adopted a one-sided proposed order verbatim without findings)
In re T.D. v. Dep’t of Child. & Fam. Servs., 924 So. 2d 827 (Fla. 2d DCA 2005) (adoption of proposed order not reversible per se; factors to evaluate)
Chetram v. Singh, 984 So. 2d 614 (Fla. 5th DCA 2008) (reversal upheld despite absence of transcript where record indicated lack of independent consideration)
C.N. v. I.G.C., 316 So. 3d 287 (Fla. 2021) (noting abrogation on other grounds of aspects of Ross)