On Tuesday, March 24, 2026, the Investigative Panel of the Florida Judicial Qualifications Commission recommended a public reprimand for Second Judicial Circuit Judge J. Layne Smith after finding he made intemperate, biased, and discourteous remarks during proceedings in Raker, Jr. v. Vause (Wakulla County Case No. 2022-CA-90).
The Panel’s findings, filed with the Florida Supreme Court, follow a self-report by Judge Smith on October 21, 2025, and an investigation that began in November 2025. Smith appeared under oath before the Commission’s Investigative Panel on December 12, 2025, admitted violations of multiple Judicial Conduct Canons, and accepted responsibility for his conduct. At the conclusion of the hearing, the Panel found probable cause and instituted formal charges.
The Commission’s report details a September 23, 2025 Order to Show Cause hearing in a family-related dispute that encompassed seven contentious matters — including petitions for injunctions for protection, an eviction with a breach-of-contract counterclaim, probate disputes, and claims to set aside a will and deeds. Frustration over possible defective service prompted the judge to make a series of derogatory and hyperbolic comments directed at the parties and their attorneys, the report states.
Reported remarks include an offhand statement about instructing a deputy “to pull his gun and shoot all three of you” followed by, “I really don’t want him to do that,” which the Commission characterized as hyperbolic and not literal. The panel also recorded comments belittling counsel as the “Keystone Cops,” the “gang who cannot shoot straight,” and the “Apple Dumpling Gang,” and admonitions that the lawyers should “man up” and “look at your bar card.” Additional comments criticized the clients as unreasonable and suggested that the judge nearly sent the matter to the appellate courts to avoid further handling.
The Commission noted Smith’s repeated references to having to “sweep up the dung that the elephant dropped” in the case and his statement that he had not had a hearing like it “the entire time I’ve been on the bench.” In a separate hearing, the judge reportedly told a litigant that determining the correctness of a sanctions motion was “not worth my time.”
The report records that Smith recused himself from the Raker matter on October 2, 2025, self-reported his behavior on October 21, 2025, and issued a public apology. He has since recused from remaining cases involving the same parties and attorneys. The Panel credited mitigation, including Smith’s admission of misconduct, cooperation with the inquiry, expression of regret over potential erosion of public confidence, a generally positive reputation since becoming a judge in 2015, and implementation of remedial practices such as taking recesses in acrimonious proceedings.
Under a stipulation pursuant to Commission Rule 6(k), Smith conceded the factual findings. The Investigative Panel concluded his conduct fell below required judicial standards and recommended a public reprimand, forwarding its recommendation to the Florida Supreme Court for review.
A copy of the original filing can be found here.
