Publix Supermarkets, Inc. v. Jonida Goga

Summary

The court rejected a specialized or heightened abuse-of-discretion standard for reviewing dismissals based on fraud on the court. It held that factual findings receive competent, substantial evidence review, legal conclusions receive de novo review, and the choice of sanction receives ordinary abuse-of-discretion review. Applying that framework, the court concluded that the evidence supported the finding of pervasive fraud and that dismissal of the entire action was reasonable.