A Florida appeals court has tossed out a child support case, ruling that state law simply doesn’t give certain parents the right to challenge administrative orders in the district court.
The Sixth District Court of Appeal issued the decision on May 1, 2026, in the case of Adrelynn Shattell Thomas v. Department of Revenue and Douglas Bernard Wyche. The court dismissed the appeal from Thomas, a mother who was seeking to overturn a paternity and support order involving her and Wyche.
While the legal battle might seem like a standard dispute, the judges found a massive “jurisdictional hurdle” in the way. Under Florida statutes, specifically section 409.2563, only the “obligor” parent—the one ordered to pay support—or the Department of Revenue has the legal standing to ask a district court to review these specific types of administrative orders.
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Because Thomas is the “obligee” parent—the one receiving the support—the court ruled she didn’t have the right to be there.
“Conspicuously absent from section 409.2563 is any language granting the same right to seek judicial review to the obligee parent,” Judge Pratt wrote in the court’s opinion.
The court explained that Florida’s system for setting up child support through administrative hearings is a “specialized statutory scheme.” While general state laws usually allow any “adversely affected” person to appeal an agency’s decision, the court held that the specific rules for child support take precedence. By naming only the paying parent and the Department as having appeal rights, the law effectively leaves the receiving parent out of the district court process for these specific orders.
The judges noted that they weren’t just being difficult; they were following the “plain text” of the law. They also pointed to a previous decision from the First District, White v. Department of Revenue, which reached the same conclusion.
“White got it right,” the court stated. “We write to explain why.”
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However, this doesn’t mean Thomas is completely out of luck if she wants to fight the ruling. The court pointed out that there is still a path forward, just not in the appeals court. If she wants to challenge the actual dollar amount of the support order, she has to take the fight to a local circuit court instead.
The ruling was unanimous, with Chief Judge Traver and Judge Stargel concurring. Thomas represented herself in the matter, while the Department of Revenue was represented by the Office of the Attorney General. Douglas Bernard Wyche did not make an appearance in the appeal.
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