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DEPARTMENT OF REVENUE, on behalf of Madison T. Adams, Petitioner, v. Owen HARRIS, Respondent.
In this certiorari proceeding, the Department of Revenue, on behalf of Madison Adams, challenges an order approving the hearing officer's recommendation to compel genetic testing to determine paternity of the minor child. We agree with the Department that the circuit court erred in approving the hearing officer's recommendation. The child support proceedings did not properly place paternity in controversy, and Respondent did not establish good cause for the testing. Fla. Fam. L. R. P. 12.360(a)(1), (2); Fla. R. Civ. P. 1.360(a)(1), (2); State, Dep't of Revenue ex rel. Chambers v. Travis, 971 So. 2d 157, 162 (Fla. 1st DCA 2007); Florida Dep't Revenue ex rel. Corbitt v. Alletag, 156 So. 3d 1110, 1112 (Fla. 1st DCA 2015). Even if paternity was in controversy and good cause was shown, the hearing officer had no authority to address a contested paternity matter. Alletag, 156 So. 3d at 1113 n.2; State v. Ceasar, 188 So. 3d 989, 991 n.1 (Fla. 1st DCA 2016); Fla. Fam. L. R. P. 12.491(e).
We Grant the petition for writ of certiorari and Quash the order compelling genetic testing.
Per Curiam.
Roberts, Winokur, and Nordby, JJ., concur.
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Docket No: No. 1D2025-0809
Decided: October 15, 2025
Court: District Court of Appeal of Florida, First District.
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FindLaw’s Learn About the Law features thousands of informational articles to help you understand your options. And if you’re ready to hire an attorney, find one in your area who can help.
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