May Appeals Court Apply 'De Novo' Standard In Reviewing Parts Of Declaratory Judgment Action?

If Appeal Challenges Rulings Other Than Whether Declaratory Relief Available

In the Matter of: Kenneth D. Arnott et al. v. James Wayne Arnott et al., Case no. 2010-2180

4th District Court of Appeals (Highland County)

ISSUE: In reviewing a trial court's decision in a declaratory judgment action, must a court of appeals apply an "abuse of discretion" standard in considering all issues ruled on by the trial court, or may the appellate court conduct a non-deferential "de novo" review of purely legal issues decided by the trial court after it determined that the complaint presented a question that was justiciable under the Declaratory Judgment Act?