BARON v. BARON (2026)

Former Wife appeals a final judgment of dissolution of marriage. We affirm on all arguments. We write only to address Former Wife's due process argument.

Former Wife argues that the trial court denied her due process by holding the trial in one day rather than in the five days requested and otherwise requiring her to present her entire claim in one day.

We disagree. The record shows that the trial court effectively managed the trial and afforded both sides adequate time to present their case while appropriately conserving court resources for other litigants.

“The failure to give a party the chance to present witnesses or testify violates the fundamental right of a full and fair opportunity to be heard in judicial proceedings.” Julia v. Julia, 146 So. 3d 516, 521 (Fla. 4th DCA 2014) (citation, brackets, and internal quotation marks omitted). And “[a]n opportunity to be heard includes the right to present evidence bearing on the issues.” Begens v. Begens, 617 So. 2d 360, 361 (Fla. 4th DCA 1993).

But that hardly entitles any party to unlimited time. And unless time is limited, it is unlimited.

“[M]atters regarding the length of legal argument and the length of a proceeding generally fall within a trial court's discretion.” Brown v. State, 894 So. 2d 137, 154 (Fla. 2004) (collecting authority). “[T]rial courts have wide latitude to regulate court proceedings before them in order that the administration of justice be speedily and fairly achieved in an orderly and dignified manner.” Saldana v. State, 295 So. 3d 1235, 1238 (Fla. 1st DCA 2020) (citation and internal quotation marks omitted). “While courts have broad authority to control their dockets, trial judges must use this authority to manage their courtrooms so that the people's business may be conducted fairly, efficiently, and expeditiously.” Julia, 146 So. 3d at 522 (citation and internal quotation marks omitted). Thus, for instance, it was not an abuse of discretion to cut off an examination where an “attorney cross-examined one witness for six hours.” Ketterson v. Est. of Bruns, 711 So. 2d 613, 613 (Fla. 4th DCA 1998).

We have said that a trial court ought to consider certain factors in deciding how much time to set aside for a matter, including the “length of trial, number of witnesses, amount of evidence, importance of the case, number and complexity of issues, amount involved and press of time.” Woodham v. Roy, 471 So. 2d 132, 134 (Fla. 4th DCA 1985). And “[i]n all events, the time must be reasonable and should permit counsel an adequate opportunity to” present their evidence and argument. Id.; accord Stockton v. State, 544 So. 2d 1006, 1009 (Fla. 1989) (“What constitutes a reasonable time depends upon the facts and circumstances of each particular case.”).

In other words, you don't get the time that you want, you get the time that you need.

The trial court must “efficiently manage trial proceedings, including avoiding the needless consumption of time.” Sullivan v. Sullivan, 736 So. 2d 103, 105 (Fla. 4th DCA 1999) (internal citation and quotation marks omitted). As we noted in Sullivan:

While pre-established time limits must flex with circumstances, the time of a trial judge is not an infinitely elastic commodity. There are other cases waiting to be heard. A full and fair hearing does not require a trial court to allow unlimited time. Imposing fair and predetermined time limits does not, standing alone, deprive a party of due process of law.

Id. In Sullivan, we noted with approval that, “[a]t the commencement of trial, the trial court announced it had a day and a half and that the time would be equally split between the parties’ presentations.” Id. And “[d]uring the trial, the court periodically advised counsel how they were managing their time.” Id.

By utilizing reasonable and equitable time management systems and announcing them in advance, trial courts, as in Sullivan, protect due process at the front end, rather than the back end, of trial—so long as the time allotted is “reasonable,” Stockton, 544 So. 2d at 1009, and each party receives their “fair share of the court's time,” Julia, 146 So. 3d at 522 (citation omitted).

Here, similar to Sullivan, the trial court announced in advance that it had allotted a full day for trial. It afforded both the parties time to present their cases. A day, considering the Woodham factors, was more than enough time to afford each party the opportunity to be heard in a relatively non-complex dissolution of marriage trial. The record shows that the trial court diligently nudged the matter along, reminded counsel of the limited time and the need to move the case forward, and redirected errant testimony. The record does not show that Former Wife was unable to present any particular witnesses or evidence on account of the time limit. Cf. Sullivan, 736 So. 2d at 105 (“At no time did wife's counsel proffer the testimony he would have procured from the father had additional time been made available․ The issue was not preserved for appeal.”).

In short, a day was ample time for Former Wife to present her case, and she in fact presented her case. The trial court did not deny her due process by imposing reasonable time limits to ensure that other litigants could have their day in court too.

Affirmed.

Lott, J.

Gerber, C.J., and Shaw, J., concur.