In In re Allen, 998 So. 2d 557 (Fla. 2008) the court concluded that Judge Allen used extrarecord materials to personally attack another judge and "this type of action in a judicial opinion cannot be condoned, nor can it be protected by judicial independence." Id.
The Court cautioned:
While we find that the doctrine of judicial independence did not preclude the Judicial Qualifications Commission ("JQC") from filing charges against Judge Allen for writing and releasing his concurring opinion in this case, we caution that our opinion today should not be viewed as a license for the JQC to judge and evaluate judicial opinions. Id.