The Tipsy Coachman doctrine is a
rule of law
The essence of the rule of law is that all people and institutions within a Body politic, political body are subject to the same laws. This concept is sometimes stated simply as "no one is above the law" or "all are equal before the law". Acco ...
that upholds in a
higher court a correct conclusion, despite flawed reasoning by the
judge
A judge is a person who wiktionary:preside, presides over court proceedings, either alone or as a part of a judicial panel. In an adversarial system, the judge hears all the witnesses and any other Evidence (law), evidence presented by the barris ...
in a lower
court
A court is an institution, often a government entity, with the authority to adjudicate legal disputes between Party (law), parties and Administration of justice, administer justice in Civil law (common law), civil, Criminal law, criminal, an ...
. In other words, the lower
judgment was right but for the wrong reason.
The colorful "tipsy coachman" label comes from a 19th-century
Georgia
Georgia most commonly refers to:
* Georgia (country), a country in the South Caucasus
* Georgia (U.S. state), a state in the southeastern United States
Georgia may also refer to:
People and fictional characters
* Georgia (name), a list of pe ...
case, ''Lee v. Porter'', 63 Ga 345, 346 (1879), in which the
Georgia Supreme Court, noting that the "human mind is so constituted that in many instances it finds the
truth
Truth or verity is the Property (philosophy), property of being in accord with fact or reality.Merriam-Webster's Online Dictionarytruth, 2005 In everyday language, it is typically ascribed to things that aim to represent reality or otherwise cor ...
when wholly unable to find the way that leads to it", quoted from
Oliver Goldsmith's ''Retaliation: A Poem'' written in 1774:
The
Florida Supreme Court
The Supreme Court of Florida is the state supreme court, highest court in the U.S. state of Florida. It consists of seven justices—one of whom serves as Chief Justice. Six members are chosen from six districts around the state to foster geog ...
explained the doctrine in a 2002
appeal
In law, an appeal is the process in which Legal case, cases are reviewed by a higher authority, where parties request a formal change to an official decision. Appeals function both as a process for error correction as well as a process of cla ...
from a
second-degree murder conviction:
{{quote,
We start with the proposition that generally, if a
claim is not raised in the
rialcourt, it will not be considered on appeal. However, notwithstanding this principle, in some circumstances, even though a
trial court
A trial court or court of first instance is a court having original jurisdiction, in which trials take place. Appeals from the decisions of trial courts are usually heard by higher courts with the power of appellate review (appellate courts). ...
's ruling is based on improper reasoning, the ruling will be upheld if there is any theory or principle of law in the
record which would support the ruling.
This longstanding principle of
appellate law, sometimes referred to as the 'tipsy coachman' doctrine, allows an appellate court to affirm a trial court that reaches the right result but for the wrong reasons so long as there is any basis which would support the judgment in the record., ''Robertson v. State'', 829 So. 2d 901, 906 (Fla. 2002) (internal citations and punctuation omitted)
External links
*An exhaustive article addressing the applicability of the principle can be found in The Florida Bar Journal at: http://www.floridabar.org/DIVCOM/JN/JNJournal01.nsf/c0d731e03de9828d852574580042ae7a/31a5fce82d401c5e8525739f004c7f9e?OpenDocument
*In yet another article in The Florida Bar Journal the efficacy of the principle is questioned at: http://www.floridabar.org/DIVCOM/JN/JNJournal01.nsf/c0d731e03de9828d852574580042ae7a/c0109640122fbcde852573050052d2ed?OpenDocument
Legal doctrines and principles