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The Trial Court Reached The Right Result For The Wrong Reason – The Tipsy Coachman

Posted by David Adelstein on December 14, 2014

The Tipsy Coachman


Trial courts sometimes reach the right result / ruling, but for the wrong reason. This wrong reason serves as the basis of an appeal.

However, under the appellate principle known as the “tipsy coachman doctrine,” an appellate court can affirm a trial court’s ruling even if the trial court reached the right result / ruling, but for the wrong reason. The right reason(s), though, needs be supported by the record before the trial court (that makes up the record before the appellate court). See Dade County School Board v. Radio Station WQBA, 731 So.2d 638 (Fla. 1999); accord State Farm Fire and Cas. Co. v. Levine, 837 So.2d 363 (Fla. 2002).

The tipsy coachman doctrine allows an appellee (party prevailing in the trial court) to respond to an appellant’s (party appealing the trial court’s ruling) appeal that the trial court’s ruling should be affirmed based on an alternative basis adequately supported by the record.


Please contact David Adelstein at dadelstein@gmail.com or (954) 361-4720 if you have questions or would like more information regarding this article. You can follow David Adelstein on Twitter @DavidAdelstein1.

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