Ulano v. Anderson

1 Citing case

  1. Verleni v. Dept. of Health

    853 So. 2d 481 (Fla. Dist. Ct. App. 2003)   Cited 3 times
    Reversing final order that adopted findings set out in exceptions to the recommended order contrary to the ALJ's findings that were supported by competent substantial evidence

    Oral pronouncements of an agency at a duly noticed hearing control over a written order which is inconsistent with those pronouncements. Cf., e.g., Ulano v. Anderson, 626 So.2d 1112 (Fla. 3d DCA 1993) ("Reversal is required where a final judgment is inconsistent with a trial court's oral pronouncements."). Beyond the normal rule requiring that a written order reflect the tribunal's earlier pronouncements, three specific considerations lead to reversal here. First, all meetings of the Board are public meetings subject to notice requirements.