Tipsy Coachman
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The Tipsy Coachman doctrine is a
rule of law The rule of law is the political philosophy that all citizens and institutions within a country, state, or community are accountable to the same laws, including lawmakers and leaders. The rule of law is defined in the ''Encyclopedia Britannica ...
that upholds in a higher court a correct conclusion, despite flawed reasoning by the
judge A judge is a person who presides over court proceedings, either alone or as a part of a panel of judges. A judge hears all the witnesses and any other evidence presented by the barristers or solicitors of the case, assesses the credibility an ...
in a lower
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. In other words, the lower
judgment Judgement (or US spelling judgment) is also known as ''adjudication'', which means the evaluation of evidence to make a decision. Judgement is also the ability to make considered decisions. The term has at least five distinct uses. Aristotle s ...
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 Caucasus region of Eurasia * Georgia (U.S. state), a state in the Southeast United States Georgia may also refer to: Places Historical states and entities * Related to the ...
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 is the property of being in accord with fact or reality.Merriam-Webster's Online Dictionarytruth 2005 In everyday language, truth is typically ascribed to things that aim to represent reality or otherwise correspond to it, such as beliefs ...
when wholly unable to find the way that leads to it," quoted from
Oliver Goldsmith Oliver Goldsmith (10 November 1728 – 4 April 1774) was an Anglo-Irish novelist, playwright, dramatist and poet, who is best known for his novel ''The Vicar of Wakefield'' (1766), his pastoral poem ''The Deserted Village'' (1770), and his pl ...
's ''Retaliation: A Poem'' written in 1774: :Here, waiter, more wine, let me sit while I'm able, :'Till all my companions sink under the table; :Then, with chaos and blunders encircling my head, :Let me ponder, and tell what I think of the dead. : ... :Here lies honest William, whose heart was a mint, :While the owner ne'er knew half the good that was in't; :The pupil of impulse, it forced him along, :His conduct still right, with his argument wrong; :Still aiming at honour, yet fearing to roam, :The coachman was tipsy, the chariot drove home; :Would you ask for his merits, alas! he had none, :What was good was spontaneous, his faults were his own. The Florida Supreme Court explained the doctrine in a 2002
appeal In law, an appeal is the process in which 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 clarifying and ...
from a second-degree murder conviction: “We start with the proposition that generally, if a claim is not raised in the
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court, 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 made by higher courts with the power of appellate review (appellate courts). Mos ...
'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 In law, an appeal is the process in which 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 clarifying and ...
, 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