## Facts

- The Florida Judicial Qualifications Commission (JQC) filed formal charges against Judge Sheldon Schapiro, a circuit judge, alleging repeated misconduct in court.
- Judge Schapiro entered a stipulation admitting the charged conduct and admitting it violated the Florida Code of Judicial Conduct and was unbecoming, brought the judiciary into disrepute, and impaired public confidence.
- In one incident, Judge Schapiro chastised an attorney as a “school child” (or similar), then ordered the attorney out of the courtroom after the attorney objected to the judge’s manner; the attorney thereafter routinely sought recusal, which the judge granted.
- In another incident, Judge Schapiro ordered an assistant state attorney to appear and try a criminal case despite her report of a severe medical condition and physician-ordered bed rest due to a potential pneumonia diagnosis.
- In another incident, Judge Schapiro screamed at a prosecutor over trial assignment practices and demeaned the matter as a “nothing case” that should be tried without advance preparation, using sarcastic admonitions about wasting the court’s time.
- The admitted conduct included a recurring pattern of berating and embarrassing attorneys, use of profane language toward counsel, and a gender-based remark to a female attorney suggesting she should act more like male attorneys who did not become emotional about cases.
- The charges alleged violations of Canon 1, Canon 2A, and Canon 3B(4) of the Florida Code of Judicial Conduct.

## Issues

1. Whether the admitted pattern of abusive and demeaning courtroom conduct violated Canons 1, 2A, and 3B(4) of the Florida Code of Judicial Conduct.
2. What discipline the Florida Supreme Court should impose after reviewing the JQC’s findings and recommended sanction based on the parties’ stipulation.

## Decision

- The Florida Supreme Court accepted the JQC’s findings and approved discipline based on Judge Schapiro’s stipulation.
- The Court found the admitted conduct violated Canons 1, 2A, and 3B(4) by reflecting inappropriate, undignified, and abusive courtroom behavior that harmed public confidence in the judiciary.
- The Court imposed public discipline consistent with the recommendation, including a public reprimand and remedial conditions (including participation in corrective measures and a public apology).

## Legal Principles

- The Florida Supreme Court has constitutional authority to review JQC findings and recommendations and gives them great weight, particularly where misconduct and violations are stipulated.
- Canon 3B(4) requires judges to be patient, dignified, and courteous toward lawyers and others; persistent incivility and humiliation of counsel can breach this duty.
- Canon 2A requires judges to act in a way that promotes public confidence in the integrity and impartiality of the judiciary; abusive demeanor and demeaning remarks can undermine that confidence even absent corruption or case-outcome bias.
- Canon 1 requires maintaining the integrity and independence of the judiciary; conduct that brings the judiciary into disrepute warrants public discipline.
- A repeated pattern of misconduct, rather than isolated incidents, is an aggravating factor supporting public sanctions and remedial measures aimed at preventing recurrence.

## Conclusion

The Florida Supreme Court disciplined a circuit judge for a sustained pattern of abusive and demeaning courtroom conduct, holding that such behavior violates core judicial-canons duties of dignity, courtesy, and maintaining public confidence, and approving a public reprimand with corrective conditions.


In re Schapiro, 845 So. 2d 170 (Fla. 2003)