Inquiry Concerning a Judge, JQC No. 2025-1109, Re: J. Layne Smith · No. SC2026-0476 (Fla.) · Decided September 24, 2026
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The Florida Supreme Court has ordered Judge J. Layne Smith of the Second Judicial Circuit to appear before the Court for a public reprimand, accepting the Judicial Qualifications Commission’s findings and its recommended discipline, which Judge Smith agreed to in a joint stipulation. According to the opinion, during a September 2025 hearing in a Wakulla County case, the judge told the parties, “I would like to tell the deputy to pull his gun and shoot all three of you as far as my level of frustration right now. I really don’t want him to do that.”
What Happened
The opinion states that Judge Smith admits he “made numerous statements that were not patient, dignified, or courteous and evidenced bias against the attorneys” while presiding over Raker v. Vause (Wakulla County Case No. 2022-CA-90). Most of the comments came on September 23, 2025, during an Order to Show Cause hearing on a motion to compel discovery. According to the opinion, Judge Smith became frustrated with the parties’ attorneys after learning they could not confirm that a party had been properly served, and over the rest of the hearing he made “numerous intemperate and caustic comments to the attorneys and the parties.”
In addition to the remark about the deputy, the Court wrote that Judge Smith “belittled the attorneys, referring to them as the ‘Keystone Cops’ and the ‘Apple Dumpling Gang.’”
On October 2, 2025, Judge Smith recused himself from the case on his own accord. On October 21, 2025, he self-reported his behavior, issued a public apology, and recused himself from any remaining cases involving the parties to that case.
What the Court Held
The Commission and Judge Smith agreed that his conduct violated Canons 1 and 2 of the Code of Judicial Conduct, which require judges to uphold the integrity of the judiciary and avoid impropriety and its appearance; Canon 3B(4), which requires judges to be “patient, dignified, and courteous” to those they deal with in an official capacity; Canon 3B(5), which requires judges to “perform judicial duties without bias or prejudice”; and Canon 3E(1), which requires disqualification where a judge’s “impartiality might reasonably be questioned.” The Court wrote that “Judge Smith’s factual admissions amply support the Commission’s legal conclusions.”
The Commission and Judge Smith jointly asked for a public reprimand. The Commission noted that Judge Smith has no prior disciplinary history and has been remorseful and cooperative throughout the proceedings. The opinion also notes that he has recused himself from all cases involving the lawyers in question and has proactively implemented procedures such as taking recesses and necessary adjournments when faced with contentious court proceedings.
The Court accepted the recommendation, adding: “Although we accept the Commission’s recommendation, we emphasize that Judge Smith’s conduct fell far below the standard of professionalism that Florida judges owe to those who appear before them.” It ordered Judge Smith to appear before the Court for the administration of a public reprimand at a time to be established by the Clerk. The opinion does not impose any sanction other than the public reprimand.
The opinion was issued per curiam, with all seven justices concurring. It states that it is not final until the time expires to file a rehearing motion and, if one is filed, until it is determined.
Why It Matters
The case was resolved by stipulation, and the Court imposed the discipline the Commission and the judge jointly recommended. The opinion recites the judge’s self-report, public apology, and recusals, and the Commission’s notes that he has no prior disciplinary history and has been remorseful and cooperative — but it also states, in the Court’s own words, that the conduct fell far below the standard of professionalism Florida judges owe to those who appear before them.
The Opinion
Download the full opinion (PDF)
| Court | Supreme Court of Florida |
| Case No. | SC2026-0476 (JQC No. 2025-1109) |
| Lower Court | Original proceeding – Judicial Qualifications Commission |
| Opinion by | Per curiam (Couriel, C.J., and Labarga, Muñiz, Grosshans, Francis, Barrios, and Tanenbaum, JJ.) |
| Decided | September 24, 2026 |
| Result | Commission’s findings accepted; public reprimand ordered |