In re E.P.N., 180 So.3d 249 (Fla. 3rd DCA 2015)

Although the majority affirmed summary denial of E.P.N.’s appeal, a dissent was filed by Justice Salter. Salter noted factual differences in E.P.N.’s case that he believed established a prima facie basis for her claims and was entitled to an evidentiary hearing on her petition. E.P.N. was released by the Office of Refugee Resettlement to her mother and her petition alleged abandonment by her father pursuant to § 39.01(15)(a) and abuse pursuant to § 39.01(15)(f) by both her mother and her father within the past two years, when she was left with a relative who beat her. Similar to other recent cases, E.P.N.’s petition was denied following a brief hearing during which no evidence was taken and the department took no position.