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Box 1757 Tallahassee, Florida 32302-1757 (850) 222-9684 ‌ Editor's Note: Editor’s Note: The following case law summaries were reported for the period July 1, 2019, through September 30, 2019. Section 1. Recent Decisions of the Florida Supreme Court. None reported. Section 2. Recent Decisions of the Florida District Courts of Appeal. Whistleblower – Public Employee – Administrative Remedies – Train operator brought action against county alleging that the county had violated the Whistle-blower's Act by suspending and dismissing him in retaliation for a letter about safety concerns. Appellate court granted petition for writ of prohibition in favor of county. The Third DCA granted county’s petition for writ of prohibition where train conductor who sued county under Whistle-blower’s Act failed to exhaust administrative remedies. Consistent with the Whistle-blower's Act, the county provided for a 60-day window from the time plaintiff was dismissed for him to file his written complaint with the Ethics Commission. Plaintiff filed his whistleblower complaint with the Ethics Commission well beyond 60 days from his dismissal. Consequently, plaintiff's Ethics Commission complaint was untimely, and he therefore failed to exhaust his administrative remedies before bringing his whistleblower action in the circuit court. The court also found that plaintiff failed to exhaust the available administrative remedies with respect to his claim for reinstatement. Although plaintiff challenged his automatic suspension and dismissal pursuant to Section 2-47 of the County Code, he failed to appeal the mayor's decision. Consequently, the trial court is also without jurisdiction over second count of the complaint. Thus, the court granted the county’s petition finding that the trial court lacked jurisdiction. Miami-Dade County v. Harris, 44 Fla. L. Weekly D1644 (Fla. 3d DCA June 26, 2019). Bert Harris – Real Property – Claim brought by historic building owner against city for city’s refusal to allow demolition of building was barred by grandfather provision. The Third DCA affirmed summary judgment in favor of city where grandfather provision barred the Bert Harris claim. The residence in question was designated a historic landmark by resolution pursuant to Section 3-1103. Plaintiff asserted that modern buyers found the residence undesirable and requested a permit to demolish the residence, but its request was denied by resolution pursuant to Section 3-1107(D). The denial was based primarily on the residence's designation as a historic landmark. The criteria used to deny the request had been in effect since 1984. Florida's Legislature enacted the Harris Act to provide a remedy for private landowners where their property has been inordinately burdened by government action, but the government action does not amount to a constitutional taking. The Legislature, however, also provided a grandfather provision. The Harris Act expressly states that its provisions do not apply to the application of any law enacted on or before May 11, 1995. The court found that the undisputed evidence reveals that Ordinance No. 2508 was enacted on August 28, 1984 – more than 10 years before the statutory cutoff date of May 11, 1995. When the city designated the residence a historic landmark in 2012, it merely applied the grandfathered-in ordinance as codified in Section 3-1103. For the same reason, when the city denied plaintiff's request for a demolition permit, it merely applied the grandfathered-in ordinance as codified in Section 3-1107(D). Consequently, the district court affirmed the summary judgment in favor of the city. Cascar, LLC v. City of Coral Gables, 44 Fla. L. Weekly D1646 (Fla. 3d DCA June 26, 2019). Administrative Law – FDLE – FDLE letter and decision denying eligibility to purchase a firearm was not a final appealable agency order. Individual sought appellate review of FDLE letter denying eligibility to purchase a firearm. A party who is adversely affected by final agency action is entitled to judicial review in a district court. An administrative order is rendered when a signed, written order is filed with the clerk of the agency. In this case, the district court stated that, even if this was an appealable order, this appeal was premature because the order has not been rendered because it was not filed with the agency clerk. The individual could seek to force the FDLE to properly render its order through a writ of mandamus. Lynch v. Florida Dep't of Law Enf't, 44 Fla. L. Weekly D1752 (Fla. 1st DCA July 9, 2019). Municipal Law – Inverse Condemnation – Property owners could not bring inverse condemnation suit when the alleged taking occurred prior to their purchase of the property. Property owners brought an inverse condemnation action against city, alleging that city committed a taking by directing storm water into a retention pond on their property. The district court affirmed the trial court’s dismissal because the alleged taking occurred prior to the purchase of the property by owners, the owners were aware of the retention pond and that it collected the run-off from the surrounding area, and there was nothing that transferred the prior owner’s potential inverse condemnation claim to the current owners. Simon v. Deer Meadows Homeowners' Ass'n, Inc., 44 Fla. L. Weekly D1763 (Fla. 1st DCA July 10, 2019). Criminal Law – Search and Seizure – Warrantless Blood Draw – Warrantless blood draw following a motor-vehicle crash with serious injuries complied with Section 316.1933, Florida Statutes, because the statute contains no requirement that law enforcement determine the cause of a crash prior to ordering a compulsory blood draw. The district court held the trial court erred in granting motion to suppress a warrantless blood draw after a traffic accident with serious injuries where probable cause was present to believe that that the defendant was under the influence of alcohol. The trial court improperly granted the motion as it opined that law enforcement failed to determine the cause of the crash prior to the blood draw. The district court determined that Section 316.1933 contains no requirement that law enforcement determine the cause of a crash prior to ordering a compulsory blood draw. The district court concluded the warrantless, compelled blood draw was constitutional as it was well-supported by both probable cause and exigent circumstances. State v. Quintanilla, 44 Fla. L. Weekly D1764 (Fla. 3d DCA July 10, 2019). Municipal Law – Torts – Sovereign Immunity – Trial court improperly entered summary judgment in favor of city where a genuine issue of material fact was present as to whether the city created a dangerous condition that it knew or should have known about. Trial court improperly entered summary judgment on the basis of sovereign immunity in favor of city where a genuine issue of material fact was present as to whether the city created a dangerous condition that it knew or should have known about. Plaintiff alleged that the city was negligent in planting palm trees with wooden supports in a roadway median obstructing the view of drivers. The district court concluded that there was conflicting evidence as to whether the placement of the palm trees constituted a danger. In reversing the lower court, the district court concluded that there is a genuine issue of material fact as to whether the city created a dangerous condition that it knew about or should have known about. Bejarano v. City of Coral Gables, 44 Fla. L. Weekly D1769 (Fla. 3d DCA July 10, 2019). Contract – Arbitration – Arbitration clause in contract required city and county to bring their claims against seller and buyer of a professional baseball team in arbitration rather than the circuit court. Where written contract has express language requiring arbitration for certain disputes, and the nature of the dispute falls within such an arbitration clause, arbitration is the appropriate initial venue for the claims. The dispute arose from a disagreement in the value of an equity payment owed to the city and county for the sale of the professional baseball team. The contract stated that any disagreement regarding the payment would be settled in arbitration. Another agreement between the seller and the city and county contained an arbitration clause which stated that any disagreements relating to the payment would be resolved in accordance with the arbitration provision. The district court concluded that, based on the express language of the contracts, the nature of the disputes identified in the city and county complaints, and applicable precedent, the trial court improperly denied the motion to stay pending arbitration. The district court remanded the case so that the city and county may file their claims in arbitration, should they elect to continue to dispute the information and report provided to them by the seller. Miami Marlins, L.P. v. Miami-Dade County, 44 Fla. L. Weekly D1772 (Fla. 3d DCA July 10, 2019). Criminal Law – Search and Seizure – Investigative Stop – Officers responding to 911 call had probable suspicion to stop defendant who was sitting in back of church during private christening wearing bulletproof vest and arrested when police officer saw firearm in his pocket during patdown. The trial court erred in granting motion to suppress firearm, magazine and bulletproof vest when defendant was questioned after he was found sitting in back of church during private christening wearing bulletproof vest and arrested when police officer saw firearm in his pocket during patdown. The trial court improperly found that officers lacked reasonable suspicion for the stop. The trial court correctly found that an officer continuing to pursue the defendant after he attempted to walk away and subsequently directing him to speak to another officer constituted a stop. One of the officers testified that at that time, defendant was not free to leave. The district court opined that a reasonable person would not feel free to leave where, after ignoring one officer and walking away, that officer continues to pursue the individual, requests him to “hold up,” and then directs him to speak to another officer. Thus, the trial court did not err in finding that the stop was a seizure under the Fourth Amendment. The district court concluded that the basis for the investigatory stop was that defendant was wearing a bulletproof vest while observing a private christening. The attendees did not know defendant, nor had they seen him at the church previously. Defendant was sitting at the back of the church by himself, and those inside the church were aware of church shootings occurring across the United States and the world. Upon noticing law enforcement, defendant began to walk in the other direction and exited the building. These facts provided law enforcement with reasonable suspicion to conduct an investigatory stop. State v. Willis, 44 Fla. L. Weekly D1806 (Fla. 5th DCA July 12, 2019). Municipal Law – Standing – City residents who brought action against city alleging lease agreements of mixed-use development on city-owned property violated city charter lacked standing. Trial court correctly dismissed complaint as plaintiffs lacked special injury necessary for standing to bring action. Plaintiff pointed to a charter amendment that eliminated lack of standing as an affirmative defense. However, such amendment was not in effect at the time of the actions and did not apply retroactively. The district court concluded that the amendment did not apply because the amendment constituted a substantive change to the city charter and there is no language or indication that it was to be applied retroactively. The district court then concluded that plaintiffs did not allege special injury sufficient to confer standing. This is because plaintiffs only alleged that they would consider submitting a bid if the city were to issue a new request for proposals. This, however, provides a mere possibility and is insufficient to meet the special injury requirement standing. The district court affirmed the trial court because the amendment did not apply retroactively to grant standing and the plaintiff lacked a special injury sufficient to create standing. Liebman v. City of Miami, 44 Fla. L. Weekly D1836 (Fla. 3d DCA July 17, 2019). Whistleblowers – Public Employees – Florida Public Whistleblower Act (FPWA) allows for the recovery of non-economic damages. Trial court erred in finding that police officer who alleged violation of FPWA was not entitled to seek noneconomic damages. The district court stated that the FPWA mandates that an award include the remedies explicitly identified within the statute but does not expressly exclude other recoverable damages, thereby allowing other forms of relief as may be appropriate under applicable law. As a result, the district court reversed the trial court's final judgment with respect to its denial of recovery of noneconomic damages under the FPWA and remanded the case for a trial on plaintiff's noneconomic compensatory damages. Iglesias v. City of Hialeah, 44 Fla. L. Weekly D1896 (Fla. 3d DCA July 24, 2019). Criminal Law – Search and Seizure – Search of vehicle occupants’ pouch officers ordered to be left in vehicle following traffic stop was permissible where the smell of marijuana provided officers with probable cause. The district court reversed an order granting a motion to suppress where officers searched a passenger’s pouch during a traffic stop where the officers smelled marijuana and a drug dog alerted to the pouch. The subject vehicle was stopped for a traffic infraction. Upon approaching the vehicle, the officers detected the odor of both fresh and burnt marijuana emanating from inside the vehicle. The smell of marijuana alone was sufficient to give the officers the requisite probable cause to search both the vehicle and its occupants. Accordingly, whether the pouch remained on the defendant's person or inside the vehicle was immaterial as the officers had probable cause to search it either way. State v. Tigner, 44 Fla. L. Weekly D1914 (Fla. 4th DCA July 24, 2019). Municipal Law – Negligence – Sovereign Immunity – Residents who lived in vicinity of city's former incinerator-wastewater treatment plant brought action against city for illegal discharge of hazardous substances, negligence and inverse condemnation. The district court found that city was not entitled to sovereign immunity on plaintiff’s medical monitoring claim where, although claim was brought in equity and no sovereign immunity exemption exists for equity claims, the claim is grounded in negligence, and thus the city is not entitled to sovereign immunity. The district court also concluded that the trial court’s ruling on sovereign immunity was not brought in a timely manner for appellate review. The trial court's ruling in 2012 was prior to the 2014 amendment adding a denial of sovereign immunity as a matter of law to rule 9.130. However, the city had an available remedy for interlocutory review. Prior to the rule amendment, a nonfinal order denying a claim of immunity from suit could be reviewed by certiorari. The city did not seek certiorari review in a timely manner but can seek review following the final order in this case. The district court also concluded that a continuing trespass can ripen to a constitutional taking and that the city was not immune from the inverse condemnation claim. The district court stated that the sufficiency of a takings claim is not reviewable by nonfinal appeal. City of Fort Lauderdale v. Hinton, 44 Fla. L. Weekly D1915 (Fla. 4th DCA July 24, 2019). Criminal Law – Search and Seizure – Investigatory Stop – Consensual Encounter – Defendant’s encounter with police was not consensual where officer ordered individuals to stop multiple times and testified that the individuals were detained. The district court reversed a trial court order denying a motion to suppress where an officer ordered an individual to stop finding that the stop was not a consensual encounter. What otherwise might have been a consensual citizen encounter becomes an investigatory stop once an officer shows authority in a manner that restrains the defendant's freedom of movement such that a reasonable person would feel compelled to comply. The individuals did not stop when first ordered to do so by the officer; in fact, the defendant loudly announced that he did not have to stop. The group only stopped after the second order from the officer, whose specific testimony was that he gave the teens a lawful order to stop and detained them. The district court opined that because the only basis offered by the trial court for its order denying the motion to suppress was its finding that this was a consensual encounter, it was compelled to reverse, as this was not a consensual encounter. N.J. v. State, 44 Fla. L. Weekly D1928 (Fla. 5th DCA July 26, 2019). Criminal Law – Search and Seizure – Expectation of Privacy – Protective Sweep – Search of defendant’s hotel room was improper where defendant was arrested outside of the hotel room in the hallway. The district court concluded that the search of defendant’s hotel room was unlawful where defendant was arrested outside of the hotel room in the hallway. The district court concluded that defendant had a reasonable expectation of privacy in his hotel room. The district court also opined that exigent circumstances were not present because the purpose for which the officers went to the hotel was accomplished when they observed another occupant's movement and searched the hotel, the defendant was in custody, and defendant posed no threat or harm to the officers. Finally, the district court rejected the contention that the search was proper as a protective sweep because the law enforcement officers lacked a reasonable, articulable suspicion that entry into the hotel room was necessary for officer safety or preservation of evidence. State v. M.B.W., 44 Fla. L. Weekly D1954 (Fla. 2d DCA July 31, 2019). Criminal Law – Search and Seizure – Standing – Defendant who was not the authorized driver of a rental car, pursuant to the rental agreement, had a reasonable expectation of privacy in the rental car and thus standing where he was in lawful possession and control of the rental car. The Second DCA concluded that a defendant who was not the authorized driver of a rental car, pursuant to the rental agreement, had a reasonable expectation of privacy in the rental car and thus standing where he was in lawful possession and control of the rental car. The district court reversed and remanded for a new hearing on the issue. The district court also addressed questioning by the prosecutor and a comment in closing argument regarding defendant’s failure to call witnesses. The district court concluded that the line of questioning by the prosecutor and the comment during closing arguments were improper because they suggested to the jury that defendant had an obligation to present evidence when he did not. The district court also commented on the prosecutor’s comments stating that a police officer would not make up a lie and sacrifice their career by perjuring themselves. The district court stated that it was an inappropriate attempt to persuade the jury that the police officer's testimony should be believed simply because he or she is a police officer and improperly suggested that police officers would not testify falsely because they have too much at stake. Jeansimon v. State, 44 Fla. L. Weekly D1959 (Fla. 2d DCA July 31, 2019). Criminal Law – Search and Seizure – Search Warrant – Search of defendant’s vehicle was lawful where warrant authorized officers to enter and search the said residence, curtilage, outbuildings, conveyances and persons located on said curtilage for items and contraband. The Fourth DCA affirmed the denial of the motion to suppress because the district court found that the search warrant in this case specifically authorized the search of any vehicles located on the property. The district court found this search to be reasonable because it was specifically authorized by a judicial officer. The district court did reverse and remand defendant’s sentence for a new sentencing hearing because the trial court improperly considered a subsequent arrest without conviction during sentencing for the primary offense. Price v. State, 44 Fla. L. Weekly D2027 (Fla. 4th DCA Aug. 7, 2019). Public Records Request – Security Plan Exemption – Good Cause – Newspaper extinguished claim that good-cause exception to security-plan exemption applied where newspaper advised trial court that they no longer wanted the recordings because recordings were no longer newsworthy. The First DCA concluded that the good-cause exception to the security-plan public records exemption did not apply where the requesting party advised the trial court that it was no longer seeking the recordings because the recordings were no longer newsworthy. The district court concluded that the trial court’s order compelling production of the records was an abuse of discretion where the requesting party disavowed the request. Regardless of whether the newspaper’s previously offered reasons for disclosure met the statutory standard, their contention that it no longer wanted the videos because they were no longer newsworthy means that they failed to show good cause sufficient to invoke the exception to exemption. Thus, the final order’s finding of good cause was unreasonable. Florida Dep't of Corr. v. Miami Herald Media Co., 44 Fla. L. Weekly D2050 (Fla. 1st DCA Aug. 9, 2019). Public Records – Jail Visitation Logs – Criminal Law – Detainee who was in jail awaiting trial on murder charges was not entitled to protective order to prevent disclosure of jail visitation logs as the logs were public records subject to disclosure. The Fourth DCA held that jail visitation logs were public records subject to disclosure even where such logs would reveal criminal defendant’s mental health experts retained in connection with his defense. The district court concluded that petitioner has satisfied the jurisdictional threshold of a showing of irreparable harm when he contends that revealing the names of experts who may consult or interview him while he is in jail would allow anyone to find information regarding the expert on the internet. Then, understanding the expert's area of expertise would provide a window into the attorney's defense strategy, thus invading attorney-client privilege and work product, and preventing him from receiving a fair trial. The court concluded that the Florida Constitution and the Public Records Act do not authorize redacting the names of the experts visiting petitioner in jail. If public policy demanded that these be kept confidential, it is for the Legislature to provide an exemption by statute. This is true even when judicially created privileges are implicated. Cruz v. State, 44 Fla. L. Weekly D2076 (Fla. 4th DCA Aug. 14, 2019). Municipal Ordinance – Preemption – Home Rule – City ordinance prohibiting food service providers and stores from selling or using expanded polystyrene containers was preempted by state law. The Third DCA held that city ordinance prohibiting the use of polystyrene containers was expressly preempted by state law. The district court concluded that statutes grandfather provision date in. Section 500.90 does not impermissibly single out the city or county, even though the city was the first municipality and regulate polystyrene after this date. The district court also concluded that no violation of the nondelegation doctrine occurred because plain text of statute provided that regulation of polystyrene products was preempted to the department, and department's rulemaking authority stemmed from separate unchallenged rulemaking section. As to whether the statute was arbitrary and capricious, the district court stated that it was not arbitrary and capricious because the only classification scheme found in Section 500.90 applies to ordinances – those enacted before and those enacted after January 1, 2016 – there is no classification of any governmental entities. Finally, the district court concluded that the city ordinance was expressly preempted. The district court found that the statutes at issue are unambiguous and that they expressly preempt the city's ordinance. Section 403.708(9) preempts regulatory control over “[t]he packaging of products manufactured or sold in the state ... .” The plain text encompasses all types of packaging, including polystyrene. Similarly, Section 403.7033 prohibits local governments from regulating “auxiliary containers.” Again, the “polystyrene containers” regulated by the city's ordinance are a type of “auxiliary container.” Finally, Section 500.90 specifically preempts the regulation of “polystyrene products.” In all three instances, the district court found the language clear and unambiguous. Florida Retail Fed'n, Inc. v. City of Coral Gables, 44 Fla. L. Weekly D2089 (Fla. 3d DCA Aug. 14, 2019). Municipal Law – Development – Marina owner who brought fraud and negligent misrepresentation action against city and its employee over their handling of owner's request for city approval to redevelop real property that was subsequently transferred did not lack standing as a matter of law to bring claim. The Second DCA held marina owner who brought fraud and negligent misrepresentation action against city and its employee over their handling of owner's request for city approval to redevelop real property did not lack standing as a matter of law to bring claim. The district court first concluded that, as to the fraud and negligent misrepresentation claim against the individual defendant, the continued ownership of the property was not necessary to pursue these claims. The district court concluded that the claims for declaratory relief and mandamus could continue because an affidavit established that the current party was authorized to act on behalf of the party with actual interest. As a result, the district court concluded that it was not evident as a matter of law that plaintiff lacked standing. Pirate's Treasure, Inc. v. City of Dunedin, 44 Fla. L. Weekly D2111 (Fla. 2d DCA Aug. 16, 2019). Municipal Law – Injunction – In action brought by former police officer challenging his termination, trial court’s granting of motion to stay the proceedings and to permit officer to bring three attorneys constituted a temporary injunction and standards required for such an injunction were not met. The Third DCA reversed a trial court order that stayed proceedings and permitted the police officer to attend the hearing with three attorneys because such an order constituted a temporary injunction. The officer requested a departmental disciplinary review board hearing. This is an administrative proceeding within the police department that is voluntary and non-binding and intended to be non-legal in nature. It allows a panel within the department to review the reprimand and make a recommendation and does not allow for attorney representation. The officer arrived at the hearing accompanied by three attorneys, but the city would only allow one attorney. He refused to attend the hearing, and it went on without him. The officer’s attorney ultimately called the judicial assistant in his related Section 112.534 case and made an emergency motion to stay the administrative proceeding, without giving the city the opportunity to respond. The court stayed the administrative proceeding and ordered that the officer be allowed to bring all counsel to the hearing. The Third DCA stated that any powers the trial court might exercise in this regard [staying the proceedings and allowing all counsel to attend the hearing] can stem only from its judicial power to issue writs or injunctions. Similarly, the part of the order that directed the city to allow private attorneys to attend inter-departmental hearings contrary to the city's procedures amounts to an injunction. The Third DCA then held that temporary injunctions are extraordinary remedies and the trial court did not meet the strict requirements that govern their issuance because the movant provided no adequate notice; no written motion; no specific supporting facts; and no verified pleading, affidavit or evidentiary basis; and the trial court did not consider the necessary factors. City of Miami v. Santos, 44 Fla. L. Weekly D2111 (Fla. 2d DCA Aug. 16, 2019). Contracts – Supervisory Control – A supervising architect owes a duty of care to a contractor hired by the county for an airport improvement project where the architect has sufficient supervisory duties over, and a close nexus with, contractor. The Fourth DCA held that a supervising architect owes a duty of care to a contractor hired by the county for an airport improvement project where the architect has sufficient supervisory duties over, and a close nexus with, contractor. In this case, the architect had contracts with the county, and testimony revealed that the architect effectively controlled the project and the contractor's fate. The architect was broadly responsible for administration of the county/contractor contract and sometimes acted as the county's representative. The architect was also responsible for on-site observational duties, which were later used to certify payment. The court held that a contractor is an incidental beneficiary absent clear intent manifested in the owner-architect contract to the contrary. Thus, the Fourth DCA vacated the summary judgment order in favor of the architect. Grace & Naeem Uddin, Inc. v. Singer Architects, Inc., 44 Fla. L. Weekly D2198 (Fla. 4th DCA Aug. 28, 2019). Education – Charter School – Funding – Statutory provisions requiring distribution of capital millage revenue and federal funds to charter schools were permissible. The First DCA held that statutory provisions requiring distribution of capital millage revenue to charter schools were permissible exercises of legislature supervisory powers and provisions requiring distribution of federal funds to charter schools were permissible exercises of the constitutional responsibility to ensure adequate education. The First DCA opined that the use of local taxes to fund charter schools does not, as the school boards assert, convert or transform those local taxes into something else because they are still being spent on a local priority. The First DCA also concluded that the school boards lacked standing on all the issues but the capital millage and federal funding issues because of the public official standing doctrine. Sch. Bd. of Collier County v. Florida Dep't of Educ., 44 Fla. L. Weekly D2210 (Fla. 1st DCA Aug. 29, 2019). Florida Election Code – Local Election – Section 100.141 dealing with notice and publication of requirements do not apply to locally called special elections. An individual sought mandamus and declaratory relief to force the county to comply with the notice and publication requirements relating to elections found in Section 100.141. The First DCA held that the notice and publication requirements of Section 100.141 do not apply to locally called special elections. The court stated the context clearly indicates that “special election” in Section 100.l41 does not refer to locally called, discretionary special elections. While the Florida Election Code's definition of “special election” is broad enough to include the local election at issue in this case, this general definition does not apply “when the context clearly indicates otherwise.” In context, Section 100.l41(3) only applies when the governor and department of state are involved in the election process. The court further stated that the omission of any publication requirement in Section 100.151, which is specifically targeted at local elections, indicates that the Florida Election Code does not require notice of the qualifying period for local elections. Taylor v. Hogan, 44 Fla. L. Weekly D2215 (Fla. 1st DCA Aug. 29, 2019). Florida Constitution – Land Acquisition Trust Fund – Spending of the Land Acquisition Trust Fund (LATF) is not restricted to use on land purchased by the State of Florida after 2015. The First DCA held that spending of the LATF revenues on certain appropriations relating to lands purchased prior to 2015 were not unconstitutional. Environmental groups challenged appropriations of revenue from the LATF to properties purchased prior to the LATF’s enactment. The First DCA concluded that the text of the LATF does not plainly limit the improvement of property to those properties only recently acquired. Instead, the plain words of the subsection, as well as the placement of the only colon in subsection (b), indicate that acquisition and improvement are separate but coequal activities for LATF revenue. Oliva v. Florida Wildlife Fed'n, Inc., 44 Fla. L. Weekly D2268 (Fla. 1st DCA Sept. 9, 2019). Municipal Law – Zoning – Second-Tier Certiorari – Circuit court departed from the essential requirements of law when it granted store’s motion to dismiss city’s appeal regarding whether a business was a nonconforming use. The Third DCA held that the circuit court, in its appellate capacity, departed from the essential requirements of law when it dismissed an appeal from its board of adjustment decision finding a business to be operating in a legal nonconforming use. The circuit court erred by failing to determine whether the city was afforded procedural due process, whether the essential requirements of law were observed and whether the board of adjustment's findings were supported by substantial competent evidence. Rather, the appellate division of the circuit court simply dismissed the petition. The Third DCA did not address the merits; instead, under the appropriate standard of review, it quashed the unelaborated dismissal order, so that the circuit court appellate division can apply the three-prong standard of review as directed by the Florida Supreme Court. City of Miami Beach v. Beach Blitz, Co., 44 Fla. L. Weekly D2281 (Fla. 3d DCA Sept. 11, 2019). Ad Valorem Taxation – Homestead Exemption – Homeowners were not entitled to homestead property exemption because they failed to establish that they had maintained permanent residence on the property during the year for which they claimed the homestead exemption. The Second DCA held that homeowners were not entitled to homestead exemption for failure to establish that they had maintained permanent residency even where they manifested their intent to establish residence on the subject property by changing their licenses and voter registration cards and abandoning their prior homestead. The district court found that the homeowners never maintained “residence” on the property because the structure had not yet been built. The district court ultimately held that, based on the plain and ordinary meaning of the constitutional provision providing the homestead exemption, to “maintain” “the permanent residence” on a piece of property, a taxpayer must preserve and continue in possession of a dwelling that the taxpayer physically occupies as a home and intends to return to whenever absent. The district court concluded further that, based on the plain and ordinary meaning of the operative constitutional provision, the homeowners were not entitled to a homestead exemption for their residential property for tax year 2015 because they did not maintain their permanent residence on the property until June 11, 2015, the date that they moved onto the subject property and the first time they physically occupied a house on that property. Baldwin v. Henriquez, 44 Fla. L. Weekly D2311 (Fla. 2d DCA Sept. 13, 2019). Ad Valorem Taxation – Homestead Exemption – Tax Lien – Homeowners improperly received homestead exemption where, even though they were permanent residents in Florida, were receiving a tax exemption in Ohio for permanent residency even though they did not intend on receiving such benefit in Ohio. The Second DCA affirmed a lower court decision finding that Florida homeowners were not entitled to homestead exemption and owed back taxes, even though the homeowners were Florida residents but received a permanent residence tax exemption in Ohio unintentionally. The Second DCA found the homeowners to be in violation of Section 196.031(5) which states “[a] person who is receiving or claiming the benefit of an ad valorem tax exemption or a tax credit in another state where permanent residency is required as a basis for the granting of that ad valorem tax exemption or tax credit is not entitled to the homestead exemption provided by this section.” The plain language of the statute controls even where it is undisputed that the homeowners did not intend that their home in Ohio serve as their permanent residence, that during the time they owned that property they were permanent residents of Florida receiving a homestead exemption on property in this state, and that through a third-party's error they received the benefit of a permanent residency-based tax exemption on their home in Ohio for several years. The Second DCA also upheld the lien and sanction against the homeowners pursuant to Section 196.161 finding that the sanctions still applied pursuant to the plain language even where the homeowners were permanent residents of Florida. Fitts v. Furst, 44 Fla. L. Weekly D2314 (Fla. 2d DCA Sept. 13, 2019). Ad Valorem Taxation – Homestead Exemption – Tax Lien – Homeowner improperly received homestead exemption in Florida while he was simultaneously receiving the benefit of a tax exemption in Wisconsin based upon permanent residency there in violation of Section 196.031(5). The Second DCA affirmed a lower court decision finding that a violation of Section 196.031(5) occurred where homeowner received Florida homestead exemption while simultaneously receiving the benefit of a tax exemption in Wisconsin based upon permanent residency there. The Second DCA adopted the reasoning set forth in Fitts v. Furst, 44 Fla. L. Weekly D2314 (Fla. 2d DCA Sept. 13, 2019) found directly above. Brielmaier v. Furst, 44 Fla. L. Weekly D2318 (Fla. 2d DCA Sept. 13, 2019). Contracts – Pension – Sovereign Immunity – Retirement boards were entitled to sovereign immunity where alleged breach of contract pursuant to the pension ordinance does not impose the express contractual obligations plaintiffs alleged were breached. The Third DCA held that retirement boards were entitled to sovereign immunity where alleged breach of contract pursuant to the pension ordinance does not impose the express contractual obligations plaintiffs alleged were breached. The plaintiffs alleged that the pension ordinance imposed a contractual duty to give accurate advice regarding the financial urgency ordinance to pension beneficiaries. The district court expressed reluctance about applying a contractual duty to situations where, under the auspices of ordinances requiring general supervision, municipal employees routinely provide advice to their colleagues and the public without meaning to waive sovereign immunity, even when the advice is mistaken. The district courted concluded that the alleged poor advice given by the employees to the plaintiffs do not constitute a breach of any express contractual duty imposed on the defendants by the ordinances. Thus, the plaintiffs have not stated causes of action for breach of contract for which the defendants have waived sovereign immunity. City of Miami Firefighters' & Police Officers' Ret. Tr. & Plan v. Castro, 44 Fla. L. Weekly D2343 (Fla. 3d DCA Sept. 18, 2019). Florida Sunshine Law – Public Meetings – Mediation communications disclosed by a governmental attorney during a shade meeting are permanently exempt from public records production. The Fourth DCA held mediation communications disclosed by a governmental attorney during a “shade” meeting are to be redacted from the transcript of the shade meeting when it becomes a public record. Plaintiffs alleged that Section 286.011(8) does not contain an explicit exception for mediation communications and that there is no provision of Chapter 119, Florida's Public Records Act, which permanently exempts the disclosure of the shade meeting transcript. The district court first concluded that mediation communications in written form are exempt from public disclosure under Chapter 119. The district court further concluded that this mediation exemption is permanent. However, the district court did remand the matter with instructions to the lower court to perform an in camera review to determine if the mediation aspects of the transcript can be redacted and therefore allow release of the shade transcript. Everglades Law Ctr., Inc. v. S. Florida Water Mgmt. Dist., 44 Fla. L. Weekly D2356 (Fla. 4th DCA Sept. 18, 2019). County – Budget – Sheriff – Sheriff had unilateral authority to transfer budgeted funds between objects without approval from board of county commissioners. The First DCA held that the sheriff had unilateral authority to transfer budgeted funds between objects without approval from board of county commissioners. The district court interpreted Section 30.53 which explicitly preserves the sheriff’s power “concerning the purchase of supplies and equipment, selection of personnel, and the hiring, firing, and setting of salaries of such personnel” as a broad preservation of all powers necessary for the sheriff to carry out the duties and responsibilities of her office, which necessarily must include authority over her budget and office's expenditures. The district court additionally found that there is no statutory requirement that the sheriff seek board approval prior to transferring funds between objects, unless such officer is in a lame duck period. Alachua County v. Darnell, 44 Fla. L. Weekly D2356 (Fla. 1st DCA Sept. 20, 2019). Criminal Law – Search and Seizure – Driver was required to stop at the stop line and cross-walk prior to turning right on red, thus driver was within municipal limits and officer had authority to make the traffic stop; and driver abandoned argument as to the legality of the warrantless search of his vehicle. The Fifth DCA held that a driver who took a right turn on red onto a street outside of the municipality was within the municipality when he committed the alleged infraction because he was required to stop at the crosswalk and stop line prior to entering into the intersection. However, the court did conclude that the trial court’s finding that the warrantless search of the vehicle was permitted search incident to arrest was improper because there would have been no physical evidence in the vehicle of the crime of fleeing and eluding. As to the trial court’s second rational that the warrantless search was permitted under the automobile exception, the district court did not address this exception, as the driver did not address this trial court finding and thus abandoned argument relating to this issue. As a result, the district court affirmed the denial of the driver’s motion to suppress. Jones v. State, 44 Fla. L. Weekly D2378 (Fla. 5th DCA Sept. 20, 2019). Criminal Law – Search and Seizure – Officer had a particularized and objective basis for suspecting a driver was unlawfully operating his automobile under the influence of alcohol or narcotics and was justified in conducting an investigatory stop where the passed-out driver was blocking the entrance to a gated community. The Second DCA held that an officer had a particularized and objective basis for suspecting a driver was unlawfully operating his automobile under the influence of alcohol or narcotics and was justified in conducting an investigatory stop where the passed-out driver was blocking the entrance to a gated community. The court concluded that an objective basis existed for the stop because it was shortly before midnight when the officer observed the driver's prolonged presence at the entry box with his car engine running and brake lights on and his subsequent failure to respond when a second vehicle whose path he was blocking repeatedly flashed its lights and honked its horn. Further, when the officer approached the vehicle, he heard the engine slowly revving on and off as if the accelerator was being depressed and then released, and then he saw the driver “passed out” behind the steering wheel; and despite the open car window, the officer was initially unable to wake the driver. State v. Welch, 44 Fla. L. Weekly D2382 (Fla. 2d DCA Sept. 20, 2019). Section 3. Recent Decisions of the U.S. Supreme Court. None Reported. Section 4. Recent Decisions of the U.S. Court of Appeals, Eleventh Circuit. First Amendment – Religion – Establishment Clause – County may allow sectarian prayer to start legislative sessions, but it must not employ discriminatory practices in the selection process of the volunteer invocation contributors. Plaintiff alleged that invocations given before board meetings violated the First and 14th Amendments, as well as the Florida Constitution. The circuit court framed its analysis with the precedent that invocations to open local government proceedings are appropriate but may not be exploited to proselytize or advance any one, or to disparage any other, faith or belief. To determine if such an evocation exceeds these limits the circuit court determines whether the opportunity has been exploited by applying a three-factor test that considers the identity of the invocation speakers, the process by which they are selected and the nature of the prayers they deliver. The circuit court concluded that the county has selected invocation speakers in a way that favors certain monotheistic religions and categorically excludes from consideration other religions solely based on their belief systems. Because some invocation givers were rejected based squarely on the nature of the religious beliefs, the county acted improperly. The county may not categorically exclude from consideration speakers from a religion simply because they do not like the nature of its beliefs. Williamson v. Brevard County, 27 Fla. L. Weekly Fed. C2143 (11th Cir. July 8, 2019); Williamson v. Brevard County, 928 F. 3d 1296 (11th Cir. 2019). Civil Rights – Law Enforcement – Excessive Force – Officer who shot child while attempting to shoot family dog was entitled to qualified immunity. The Eleventh Circuit reversed the district court’s denial of a motion to dismiss on the basis of qualified immunity where a law enforcement officer shot a child while attempting to shoot a family dog. An attempt to apprehend a criminal suspect spilled over into plaintiff’s yard that had one adult, six minor children and a dog. Officers ordered all of the individuals to the ground, and when a dog approached the situation, an officer fired at the dog. The shot missed the dog and struck one of the minor children. Plaintiff sued the officer individually and on behalf of her minor child for excessive force. The circuit initially concluded that the minor child, as an innocent bystander at the site of an arrest, who was ordered to the ground by law enforcement with guns drawn, was seized under the Fourth Amendment. However, the circuit court concluded that a clearly established right was not violated. Qualified immunity analysis requires a clearly established right to be defined with specificity, not a general finding that excessive force is a clearly established right. The circuit court concluded that the officer was entitled to qualified immunity because, at the time of the incident giving rise to this case, there was no clearly established law making it apparent to any reasonable officer that firing at the dog and accidentally shooting a minor would violate the Fourth Amendment. Corbitt v. Vickers, 27 Fla. L. Weekly Fed. C2166 (11th Cir. July 10, 2019); Corbitt v. Vickers, 929 F. 3d 1304 (11th Cir. 2019). Civil Rights – Red Light Camera – Local Ordinance – Motorists who had received citations challenged enforcement scheme and penalties of red-light camera citations by filing Section 1983 action against city had standing but did not sufficiently allege a violation of their constitutional rights. Circuit court vacated order dismissing plaintiffs’ complaint for lack of standing and remanded the action to the district court for further proceedings. City adopted an ordinance that permitted the installation and operation of cameras to enforce traffic-control-device violations at certain intersections through civil penalties. The circuit opined that because plaintiffs received a civil penalty under the ordinance, and because they challenge the constitutionality of that ordinance as a whole, they have standing to bring their damages claims. But plaintiffs did not have standing to seek injunctive relief as they failed to plead facts sufficient to show a likelihood of future harm. The circuit court concluded that the punishment was civil rather than criminal because it stated as such and served the non-criminal interest of public safety. As a result of providing a civil punishment, plaintiffs’ claims that the ordinance imposed a criminal penalty without sufficient Fifth and Sixth Amendment protections must fail. Plaintiffs’ claim that their First Amendment rights have been violated by being unable to petition the courts for redress must also fail. The ordinance itself allows for the result of the administrative hearing to be appealed to the circuit court in the county. The circuit court also concluded that the ordinance did not violate substantive or procedural due process rights because (1) plaintiffs fail to allege that the ordinance violated their fundamental rights, and because the ordinance is rationally related to a legitimate government purpose of public safety; and (2) the review procedures provided in the ordinance are constitutionally sufficient. Worthy v. City of Phenix City, Alabama, 27 Fla. L. Weekly Fed. C2179 (11th Cir. July 18, 2019). Housing – Fair Housing Act – Discrimination – City lacked standing to bring suit against lender alleging that, through practices of redlining and reverse redlining, it had engaged in discriminatory or predatory lending in violation of the Fair Housing Act. The Eleventh Circuit concluded that city lacked standing to bring suit against lender alleging that, through practices of redlining and reverse redlining, it had engaged in discriminatory or predatory lending in violation of the Fair Housing Act. The circuit court opined that the city had standing so long as one of the loans challenged as discriminatory had caused or would cause city to suffer a de facto injury redressable by a favorable decision. However, city did not have standing because it did not allege that it received loans from lender, did not provide evidence of single delinquent loan identified in expert's report and only speculated that certain loans would likely go into foreclosure. This did not establish a certainly impending risk that city would lose property-tax revenues or be forced to increase municipal spending to remediate blight. The circuit court also concluded that that the summary judgment standard of standing was appropriate because discovery had occurred, there was no outstanding discovery, and the city did not advise the district court that it needed further discovery. City of Miami Gardens v. Wells Fargo & Co., 28 Fla. L. Weekly Fed. C57 (11th Cir. July 30, 2019). City of Miami Gardens v. Wells Fargo & Co., 931 F.3d 1274 (11th Cir. 2019). Criminal Law – Deprivation of Rights – Officers who punched and kicked suspects after a high-speed chase used excessive force. The Eleventh Circuit found that an officer used excessive force where the officer does not dispute that he repeatedly struck, kicked and twice used a Taser against the suspect, where he acknowledged that the only circumstance justifying his use of force was failure to comply with verbal commands. The circuit court found this use of force to be willful because a fellow officer testified that punching, kicking and employing a Taser against a passively resisting passing clearly violated the department’s policies on the use of force. The witness further testified that the officer had been most recently trained on the use of force five months before the incident. Where an officer’s actions so obviously violate his training on the use of force, a jury may infer that the violation was willful. The circuit court also concluded that a fellow officer obstructed justice by giving knowingly misleading statements related to the investigation. The circuit court concluded that a reasonable jury could infer the officer’s intent from the stark difference in his memory about the incident on the one hand and his inability to recall basic facts about his subordinates’ officer reports on the other. United States v. Brown, 28 Fla. L. Weekly Fed. C98 (11th Cir. Aug. 14, 2019). Tort – Negligence – Vicarious Liability – Individual who was shot five times during wellness check was able to maintain vicarious liability suit against sheriff for negligent conduct of deputies. The Eleventh Circuit affirmed a jury verdict against a sheriff for vicarious liability for the negligent conduct of his deputies during a wellness check that resulted in the individual whose wellness was to be checked being shot five times. The circuit court first addressed what law applies – state or federal – when deciding whether a district court judge properly informed the jury about the legal effect of its finding under state law. The circuit court joined the Seventh Circuit in holding that this issue is controlled by federal law as it pertains to procedure, not substance. The circuit court then held that a trial judge is not precluded from informing jurors about the legal effects of their factual findings, even where no general duty exists to do so. The circuit court concluded that defense counsel’s Golden Rule argument in closing was not improper because it was connected to an element or factor genuinely at issue in the case, or their focus on either a party’s behavior or perception of an incident. The argument went directly to the reasonableness of the plaintiff’s response to the deputies’ actions during the wellness check, which bears directly on the foreseeability of her actions. Finally, the circuit court concluded that the admission of any improper prejudicial character evidence was harmless because the questioning related to it was brief and limited to generalities and that all witnesses were asked the same questions relating to their employment and this witness was not singled out. Thus, the circuit court affirmed trial court verdict. Ermini v. Scott, 28 Fla. L. Weekly Fed. C298 (11th Cir. Sept. 10, 2019). Civil Rights – Employment Discrimination – Police detective brought action against city and city police chief, alleging that she was terminated based on her race, gender and disability in violation of § 1981. The Eleventh Circuit held that detective alleged sufficient evidence to establish a disability; summary judgment was not warranted on detective's ADA claim; summary judgment was not warranted on detective's racial discrimination claims; and city was not subject to liability under Section 1983 for assistant police chief's allegedly discriminatory decisions. The circuit court concluded that sufficient evidence existed that one could conclude that exposure to pepper spray and Taser shocks are not an essential function of a detective job and thus plaintiff made a prima facia showing of disability. Additionally, the circuit court concluded that the court cannot yet determine if plaintiff is a direct threat because the duties have not yet been established. The circuit court also concluded that that plaintiff has presented sufficient circumstantial evidence to raise an issue of material fact as to whether she was discriminated against on the basis of sex and race. Plaintiff alleged (1) the department initiated indefinite administrative leave yet a week later terminated her for being absent without leave; (2) the department gave no warning that if plaintiff exercised the option to use her accrued leave in lieu of being on unpaid status, she would be terminated upon exhausting her accrued leave; and (3) the department gave plaintiff no notice that she had to file FMLA paperwork by any specific date, nor did the department’s written FMLA policy provide any such deadline. Additionally, the circuit court found that evidence existed to show that the department’s reasons for terminating plaintiff were pretextual. Finally, the circuit court concluded that the municipality was not subject to liability, as it is a municipality and the decision to terminate was subject to a meaningful review. Lewis v. City of Union City, Georgia, 28 Fla. L. Weekly C145 (11th Cir. Aug. 15, 2019). Municipal Law – Ordinance – Tying – Electric utility brought action under Sherman Act and Clayton Act alleging that city ordinance requiring new homes or businesses in developments outside city limits to install gas appliances in order to receive water service from city constituted unlawful tying arrangement. The Eleventh Circuit held that city was not entitled to state-action immunity because city's use of its water monopoly to increase its share of energy market was not inherent, logical, or ordinary result of legislative scheme permitting city to provide water service, and thus city was not entitled to state-action immunity from liability under federal antitrust laws in action alleging that city ordinance requiring new homes or businesses in developments outside city limits to install gas appliances in order to receive water service from city constituted unlawful tying arrangement. Diverse Power, Inc. v. City of LaGrange, Georgia, 28 Fla. L. Weekly Fed. C155 (11th Cir. Aug. 20, 2019). Civil Rights – Law Enforcement – Excessive Force – Officer did not use excessive force during an arrest when he allegedly pulled arrestee’s arms too far behind her back, cinched the cuffs too tight and tugged on her fingers and arms to remove her rings. The circuit court found that probable cause was present where victim provided detailed account of battery and that officer did not use excessive force when he allegedly pulled arrestee’s arms too far behind her back, cinched the cuffs too tight and tugged on her fingers and arms to remove her rings. The circuit court determined probable cause was present because he had the victim’s 911 call identifying arrestee as her assailant and, more importantly, the officer had (twice over) victim's sworn statement in which she alleged that arrestee had “pull[ed] [her] hair” and “punch[ed] [her] in the face.” The circuit court also found that the officer did not use excessive force because, even though arrestee exhibited no meaningful flight risk, and even though her crime was relatively minor, the force employed by the officer here wasn't remotely unusual or disproportionate. Officers routinely pull arrestees' arms behind their backs, and the circuit court has repeatedly held that painful handcuffing alone doesn't constitute excessive force. Huebner v. Bradshaw, 28 Fla. L. Weekly Fed. C186 (11th Cir. Aug. 22, 2019). Section 5. Recent Decisions of the U.S. District Courts for Florida. None Reported. Section 6. Announcements. FMAA Seminar Notebooks Available Notebooks from the 2019 FMAA Seminar are available for $175 each. Notebooks from the 2018 FMAA Seminar are available for $150, and notebooks from prior years are available for $125 each. Please contact Lisa Dove at (850) 222-9684 or ldove@flcities.com to place your order. Section 7. Attorney General Opinions of Note. Number: AGO 2019-05 Date: August 16, 2019 Subject: Community development district board voting zones 1. Are community development districts permitted to create voting zones within the district and to have an elector residing in each such zone be elected by the district’s qualified electors to the board of supervisors? 2. If so, may the community development district take the administrative action of establishing such voting zones? There are no provisions in Chapter 190 that authorize a district to develop its own election procedures or modify the procedures set forth in Section 190.006, Florida Statutes (2018). Section 190.006(3)(a)1 only requires elected board members to be “qualified electors of the district,” whereas the procedure you propose would also require at least some of the board members to be qualified electors of a particular zone within the district, and therefore is not authorized. It is my opinion that the grant of powers in Chapter 190 does not encompass an implied administrative authority to create zones within the District and to require supervisor candidates to reside in particular zones in order to qualify for election to the Board of Supervisors. Number: AGO 2019-06 Date: August 16, 2019 Subject: Ad valorem taxation, municipal aircraft hangar leases 1. Whether city-owned and operated hangars at the Fernandina Beach Municipal Airport are exempt from ad valorem taxation pursuant to Article VII, Section 3(a) of the Florida Constitution (2018), when spaces inside the hangars are periodically leased to private aircraft owners to store airplanes. The leasehold interests owned by Fernandina Beach and leased to private aircraft owners are exempt from ad valorem taxation under Section 196.199(2)(a), Florida Statutes (2018), so long as the lessees are using the leaseholds for a noncommercial aviation or airport purpose or operation with no engagement in for-profit activity. Number: AGO 2019-07 Date: August 16, 2019 Subject: Vacation rentals, municipalities, grandfather provision 1. May a city change its table of permitted uses for zoning districts to allow vacation rentals within districts in which they were not allowed under the city’s pre-2011 ordinance and still preserve the “grandfathered” status of its pre-2011 ordinance under Section 509.032(7)(b), Florida Statutes (2018)? Amending an ordinance that was enacted prior to June 1, 2011, will not invalidate the grandfathering protection for those provisions that are reenacted, but new provisions would be preempted if they revise such language in a manner that would regulate the duration or frequency of rental of vacation rentals, even when such regulation would be considered “less restrictive” than the prior local law. Number: AGO 2019-08 Date: August 16, 2019 Subject: Public records, cybersecurity testing 1. Does Chapter 119 preclude “an agency covered by that chapter” from engaging a “vendor to conduct penetration testing of the agency’s electronic data storage systems for the purpose of detecting and remedying vulnerabilities” where such testing would potentially allow the vendor “to have access to information that is exempt from disclosure under Sections 119.071(4)(d)2.a & d, Florida Statutes (2018), and confidential under Section 119.071(4)(a)l., Florida Statutes” (pertaining to social security numbers)? If the trustees determine that the vendor penetration testing will be “for the purpose of the administration of a pension fund” within the meaning of Section 119.071(5), then it appears that any incidental disclosure to the cybersecurity vendor conducting penetration testing under a confidentiality and non-disclosure agreement would not violate Chapter 119, Florida Statutes. Additionally, potential access to or incidental release of exempt information about law enforcement personnel and firefighters to a vendor under a confidentiality agreement, for the purpose of ascertaining and ensuring its cybersecurity, would not appear to be inconsistent with the purpose underlying the exemption (i.e., ensuring the safety of such personnel), if the trustees determine there is a “substantial policy need” to undertake the vendor penetration testing (as ultimately proposed to be implemented). Number: AGO 2019-09 Date: August 16, 2019 Subject: Special district, absentee voting 1. Does Chapter 298, Florida Statutes or general Florida law authorize or otherwise permit the use of absentee ballots by landowners voting for seats of the district board at the annual landowners’ meeting? There is no language in the district’s charter or in the statutes that control district elections that authorizes voting by mail in district landowner elections. It is therefore my opinion that the Central County Water Control District may not permit landowners to use absentee ballots when voting for district members at the annual landowners’ meetings. Number: AGO 2019-10 Date: September 11, 2019 Subject: Audit exemption to extend discretionary sales surtax 1. Does Section 212.055(11)(d), Florida Statutes, which exempts a county from obtaining a performance audit when voters are being asked to adopt “the same discretionary surtax” as the surtax being replaced, require only the surtax rate to be the same, or does it also require the duration of the surtax as described in the enacting ordinance and ballot question to be the same? To be exempt from the requirement of a performance audit pursuant to Section 212.055(11)(d), Florida Statutes, the proposed discretionary sales surtax being voted upon must be the same as the immediately preceding surtax in all material respects, which would include the duration of the tax if duration was included in the preceding surtax. It is therefore my opinion that a local government is exempt from obtaining a performance audit pursuant to Section 212.055(11)(d), Florida Statutes, when the discretionary sales surtax being voted upon is the same in all material respects as the prior surtax, which would encompass duration of the tax if such is included in the prior surtax. Florida Municipal Attorneys Association 301 S. Bronough Street, Suite 300 Post Office Box 1757 (32302-1757) Tallahassee, FL 32301 Email us <mailto:ldove@flcities.com> | (850) 222-9684 | Visit our website <http://r20.rs6.net/tn.jsp?f=001CGL3gGknO4q3UN8AxpxlCTwyKGgbkZypNstFK-JHKYm7y-145NVAfSBAWwoWvzg-qs40nvlNAShCby4aGkyylkHuv5nb 7PHtX_HzQfFlFPAYMTp-6Hon_P1wfSWI7ufsBRdNzlzNc38=&c=8ZH8Cisr391VrNh2d6xtx9IW_WmK9eI4ibCMn32DhfgdnQ7UKZ2L5w==&ch=9cqInyazM-hv05zPou2I-iBduO7q_lWDmFw81J6niCevfRAggJk81g==> Unsubscribe <http://r20.rs6.net/tn.jsp?f=001CGL3gGknO4q3UN8AxpxlCTwyKGgbkZypNstFK-JHKYm7y-145NVAfSBAWwoWvzg-NLpoa9IVmITYB8p5kYUtwx7SyeGZ0csSDurad9IhbqpSJ3jG8gDrVnJoYL3fhb8XTU8IlPZDbuG1AZocshCk34Obl0F cVghWqRaJDN88T_2V0OdLT-KAVu2_dl8euptGEBACuD5bny8R87g3AqKvq4k2nMIW7RPqgvaNsC2iw8yqHC9_UU3NTafQmDS2pLJ1mtKyr5f0nYA5DTQn_5i_bZTa6QHskyBbd4g3BgeAfI2xp7d6Uqx97tK9MD8wPwzQ7hieokbtjCKCXLosZD479CTB2N3SOcbTob VdeBaVX5jW5OvIQpelG3w8zJqmrK57-mFuflNQg0pdsmsoYx53krJGImbFnfUTzeopyF7PuKz2y1CeY3fzp2f-RBQThwuBU1SgmGHzDzot4uTrFsNOpBDExFDgaNU9CKq1d0ps2qrHokmfBrk2A7QbPvdKo2AeDZ9HmsRgzNINdlrJ3vpW1Jl0RCLPIqhUaQZan2mAB KCo6jpkb_tD6dh8oeM1Dh275NsQ5epv-YLhnZBPbF58L8keStulAMqpZ2Wck0S6TaTmGAwWlQE98O2cXt9CK6Dzja7A4GEv3lCIbEQSpWGJiTc4nKLf4EzpnSt6yLzlkH4W6t4jzbnnTWavAfJ59GrCtCcc8zcz8Zd7uOdUmTsTCMYFsjwZ3QNZBAdGgCMKu_8=&c=8 ZH8Cisr391VrNh2d6xtx9IW_WmK9eI4ibCMn32DhfgdnQ7UKZ2L5w==&ch=9cqInyazM-hv05zPou2I-iBduO7q_lWDmFw81J6niCevfRAggJk81g==> Florida League of Cities | 301 S. Bronough Street, Suite 300, Tallahassee, FL 32301 Unsubscribe tnazzaro@gulf-stream.org <https://visitor.constantcontact.com/do?p=un&m=001vA4gfO5Cib2gQRogi-gDBg%3D&ch=88c631c4-d4a5-11e9-bbb0-d4ae527b8053&ca=b537053f-9407-4655-99d5-64d164512a8e> Update Profile <https://visitor.constantcontact.com/do?p=oo&m=001vA4gfO5Cib2gQRogi-gDBg%3D&ch=88c631c4-d4a5-11e9-bbb0-d4ae527b8053&ca=b537053f-9407-4655-99d5-64d164512a8e> | About Constant Contact <http://www.constantcontact.com/legal/about-constant-contact> Sent by ldove@flcities.com <mailto:ldove@flcities.com> A79B7B6602C5B54988788D107A7AF665@namprd09.prod.outlook.com <1133223060960.1104469773505.1750576391.0.1771640JL.2002@scheduler.constantcontact.com> <https://visitor.constantcontact.com/do?p=un&m=001vA4gfO5Cib2gQRogi-gDBg%3D%3D&se=001oyGoxlArFRNZkErBXuAwkg%3D%3D&t=001EkZLEx15CcE%3D&llr=bgtoyteab> [NOTICE: This message originated outside of the Town of Gulfstream -- DO NOT CLICK on links or open attachments unless you are sure the content is safe.] Florida Municipal Law Reporter 301 South Bronough Street, Suite 300 (32301) P.O. Box 1757 Florida Municipal Attorneys Association Trey Nazzaro SMTP ldove@flcities.com EX /O=EXCHANGELABS/OU=EXCHANGE ADMINISTRATIVE GROUP (FYDIBOHF23SPDLT)/CN=RECIPIENTS/CN=4F2A29F2B5E049B995E816021A4AFFE0-TNAZZARO Florida Municipal Attorneys Association Florida Municipal Attorneys Association 4F2A29F2B5E049B995E816021A4AFFE0-TNAZZARO 4F2A29F2B5E049B995E816021A4AFFE0-TNAZZARO Florida Municipal Attorneys Association Trey Nazzaro ldove@flcities.com ldove@flcities.com tnazzaro@gulf-stream.org tnazzaro@gulf-stream.org ldove@flcities.com tnazzaro@gulf-stream.org BT=7;II=<invalid>;TFR=NotForking;FIXUP=8.9051;Version=Version 15.20 (Build 2347.0), Stage=H12;UP=10;DP=1C5;QT=9 en <?xml version="1.0" encoding="utf-16"?> <PhoneSet> <Version>15.0.0.0</Version> <Phones> <Phone StartIndex="139"> <PhoneString>8502229684</PhoneString> <OriginalPhoneString>(850) 222-9684</OriginalPhoneString> </Phone> </Phones> </PhoneSet> Pass (protection.outlook.com: domain of in.constantcontact.com designates 208.75.123.177 as permitted sender) receiver=protection.outlook.com; client-ip=208.75.123.177; helo=ccm177.constantcontact.co m; BL0GCC02FT006.eop-gcc02.prod.protection.outlook.com <?xml version="1.0" encoding="utf-16"?> <AddressSet> <Version>15.0.0.0</Version> <Addresses> <Address StartIndex="45">301 South Bronough Street, Suite 300 (32301) P.O. 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sip:tnazzaro@gulf-stream.org[NOTICE: This message originated outside of the Town of Gulfstream -- DO NOT CLICK on links or open attachments unless you are sure the content is safe.] http://r20.rs6.net/on.jsp?ca=b537053f-9407-4655-99d5-64d164512a8e&a=1104469773505&c=888c3d16-d4a5-11e9-bbb0-d4ae527b8053&ch=88c631c4-d4a5-11e9-bbb0-d4ae527b8053 https://files.constantcontact.com/1cc47872101/3fbc1c3e-93b1-446e-96ac-75c62561eced.png Florida Municipal Law Reporter 301 South Bronough Street, Suite 300 (32301) P.O. Box 1757 Tallahassee, Florida 32302-1757 (850) 222-9684 ‌ Editor's Note: Editor’s Note: The following case law summaries were reported for the period July 1, 2019, through September 30, 2019. Section 1. Recent Decisions of the Florida Supreme Court. None reported. Section 2. Recent Decisions of the Florida District Courts of Appeal. Whistleblower – Public Employee – Administrative Remedies – Train operator brought action against county alleging that the county had violated the Whistle-blower's Act by suspending and dismissing him in retaliation for a letter about safety concerns. Appellate court granted petition for writ of prohibition in favor of county. The Third DCA granted county’s petition for writ of prohibition where train conductor who sued county under Whistle-blower’s Act failed to exhaust administrative remedies. Consistent with the Whistle-blower's Act, the county provided for a 60-day window from the time plaintiff was dismissed for him to file his written complaint with the Ethics Commission. Plaintiff filed his whistleblower complaint with the Ethics Commission well beyond 60 days from his dismissal. Consequently, plaintiff's Ethics Commission complaint was untimely, and he therefore failed to exhaust his administrative remedies before bringing his whistleblower action in the circuit court. The court also found that plaintiff failed to exhaust the available administrative remedies with respect to his claim for reinstatement. Although plaintiff challenged his automatic suspension and dismissal pursuant to Section 2-47 of the County Code, he failed to appeal the mayor's decision. Consequently, the trial court is also without jurisdiction over second count of the complaint. Thus, the court granted the county’s petition finding that the trial court lacked jurisdiction. Miami-Dade County v. Harris, 44 Fla. L. Weekly D1644 (Fla. 3d DCA June 26, 2019). Bert Harris – Real Property – Claim brought by historic building owner against city for city’s refusal to allow demolition of building was barred by grandfather provision. The Third DCA affirmed summary judgment in favor of city where grandfather provision barred the Bert Harris claim. The residence in question was designated a historic landmark by resolution pursuant to Section 3-1103. Plaintiff asserted that modern buyers found the residence undesirable and requested a permit to demolish the residence, but its request was denied by resolution pursuant to Section 3-1107(D). The denial was based primarily on the residence's designation as a historic landmark. The criteria used to deny the request had been in effect since 1984. Florida's Legislature enacted the Harris Act to provide a remedy for private landowners where their property has been inordinately burdened by government action, but the government action does not amount to a constitutional taking. The Legislature, however, also provided a grandfather provision. The Harris Act expressly states that its provisions do not apply to the application of any law enacted on or before May 11, 1995. The court found that the undisputed evidence reveals that Ordinance No. 2508 was enacted on August 28, 1984 – more than 10 years before the statutory cutoff date of May 11, 1995. When the city designated the residence a historic landmark in 2012, it merely applied the grandfathered-in ordinance as codified in Section 3-1103. For the same reason, when the city denied plaintiff's request for a demolition permit, it merely applied the grandfathered-in ordinance as codified in Section 3-1107(D). Consequently, the district court affirmed the summary judgment in favor of the city. Cascar, LLC v. City of Coral Gables, 44 Fla. L. Weekly D1646 (Fla. 3d DCA June 26, 2019). Administrative Law – FDLE – FDLE letter and decision denying eligibility to purchase a firearm was not a final appealable agency order. Individual sought appellate review of FDLE letter denying eligibility to purchase a firearm. A party who is adversely affected by final agency action is entitled to judicial review in a district court. An administrative order is rendered when a signed, written order is filed with the clerk of the agency. In this case, the district court stated that, even if this was an appealable order, this appeal was premature because the order has not been rendered because it was not filed with the agency clerk. The individual could seek to force the FDLE to properly render its order through a writ of mandamus. Lynch v. Florida Dep't of Law Enf't, 44 Fla. L. Weekly D1752 (Fla. 1st DCA July 9, 2019). Municipal Law – Inverse Condemnation – Property owners could not bring inverse condemnation suit when the alleged taking occurred prior to their purchase of the property. Property owners brought an inverse condemnation action against city, alleging that city committed a taking by directing storm water into a retention pond on their property. The district court affirmed the trial court’s dismissal because the alleged taking occurred prior to the purchase of the property by owners, the owners were aware of the retention pond and that it collected the run-off from the surrounding area, and there was nothing that transferred the prior owner’s potential inverse condemnation claim to the current owners. Simon v. Deer Meadows Homeowners' Ass'n, Inc., 44 Fla. L. Weekly D1763 (Fla. 1st DCA July 10, 2019). Criminal Law – Search and Seizure – Warrantless Blood Draw – Warrantless blood draw following a motor-vehicle crash with serious injuries complied with Section 316.1933, Florida Statutes, because the statute contains no requirement that law enforcement determine the cause of a crash prior to ordering a compulsory blood draw. The district court held the trial court erred in granting motion to suppress a warrantless blood draw after a traffic accident with serious injuries where probable cause was present to believe that that the defendant was under the influence of alcohol. The trial court improperly granted the motion as it opined that law enforcement failed to determine the cause of the crash prior to the blood draw. The district court determined that Section 316.1933 contains no requirement that law enforcement determine the cause of a crash prior to ordering a compulsory blood draw. The district court concluded the warrantless, compelled blood draw was constitutional as it was well-supported by both probable cause and exigent circumstances. State v. Quintanilla, 44 Fla. L. Weekly D1764 (Fla. 3d DCA July 10, 2019). Municipal Law – Torts – Sovereign Immunity – Trial court improperly entered summary judgment in favor of city where a genuine issue of material fact was present as to whether the city created a dangerous condition that it knew or should have known about. Trial court improperly entered summary judgment on the basis of sovereign immunity in favor of city where a genuine issue of material fact was present as to whether the city created a dangerous condition that it knew or should have known about. Plaintiff alleged that the city was negligent in planting palm trees with wooden supports in a roadway median obstructing the view of drivers. The district court concluded that there was conflicting evidence as to whether the placement of the palm trees constituted a danger. In reversing the lower court, the district court concluded that there is a genuine issue of material fact as to whether the city created a dangerous condition that it knew about or should have known about. Bejarano v. City of Coral Gables, 44 Fla. L. Weekly D1769 (Fla. 3d DCA July 10, 2019). Contract – Arbitration – Arbitration clause in contract required city and county to bring their claims against seller and buyer of a professional baseball team in arbitration rather than the circuit court. Where written contract has express language requiring arbitration for certain disputes, and the nature of the dispute falls within such an arbitration clause, arbitration is the appropriate initial venue for the claims. The dispute arose from a disagreement in the value of an equity payment owed to the city and county for the sale of the professional baseball team. The contract stated that any disagreement regarding the payment would be settled in arbitration. Another agreement between the seller and the city and county contained an arbitration clause which stated that any disagreements relating to the payment would be resolved in accordance with the arbitration provision. The district court concluded that, based on the express language of the contracts, the nature of the disputes identified in the city and county complaints, and applicable precedent, the trial court improperly denied the motion to stay pending arbitration. The district court remanded the case so that the city and county may file their claims in arbitration, should they elect to continue to dispute the information and report provided to them by the seller. Miami Marlins, L.P. v. Miami-Dade County, 44 Fla. L. Weekly D1772 (Fla. 3d DCA July 10, 2019). Criminal Law – Search and Seizure – Investigative Stop – Officers responding to 911 call had probable suspicion to stop defendant who was sitting in back of church during private christening wearing bulletproof vest and arrested when police officer saw firearm in his pocket during patdown. The trial court erred in granting motion to suppress firearm, magazine and bulletproof vest when defendant was questioned after he was found sitting in back of church during private christening wearing bulletproof vest and arrested when police officer saw firearm in his pocket during patdown. The trial court improperly found that officers lacked reasonable suspicion for the stop. The trial court correctly found that an officer continuing to pursue the defendant after he attempted to walk away and subsequently directing him to speak to another officer constituted a stop. One of the officers testified that at that time, defendant was not free to leave. The district court opined that a reasonable person would not feel free to leave where, after ignoring one officer and walking away, that officer continues to pursue the individual, requests him to “hold up,” and then directs him to speak to another officer. Thus, the trial court did not err in finding that the stop was a seizure under the Fourth Amendment. The district court concluded that the basis for the investigatory stop was that defendant was wearing a bulletproof vest while observing a private christening. The attendees did not know defendant, nor had they seen him at the church previously. Defendant was sitting at the back of the church by himself, and those inside the church were aware of church shootings occurring across the United States and the world. Upon noticing law enforcement, defendant began to walk in the other direction and exited the building. These facts provided law enforcement with reasonable suspicion to conduct an investigatory stop. State v. Willis, 44 Fla. L. Weekly D1806 (Fla. 5th DCA July 12, 2019). Municipal Law – Standing – City residents who brought action against city alleging lease agreements of mixed-use development on city-owned property violated city charter lacked standing. Trial court correctly dismissed complaint as plaintiffs lacked special injury necessary for standing to bring action. Plaintiff pointed to a charter amendment that eliminated lack of standing as an affirmative defense. However, such amendment was not in effect at the time of the actions and did not apply retroactively. The district court concluded that the amendment did not apply because the amendment constituted a substantive change to the city charter and there is no language or indication that it was to be applied retroactively. The district court then concluded that plaintiffs did not allege special injury sufficient to confer standing. This is because plaintiffs only alleged that they would consider submitting a bid if the city were to issue a new request for proposals. This, however, provides a mere possibility and is insufficient to meet the special injury requirement standing. The district court affirmed the trial court because the amendment did not apply retroactively to grant standing and the plaintiff lacked a special injury sufficient to create standing. Liebman v. City of Miami, 44 Fla. L. Weekly D1836 (Fla. 3d DCA July 17, 2019). Whistleblowers – Public Employees – Florida Public Whistleblower Act (FPWA) allows for the recovery of non-economic damages. Trial court erred in finding that police officer who alleged violation of FPWA was not entitled to seek noneconomic damages. The district court stated that the FPWA mandates that an award include the remedies explicitly identified within the statute but does not expressly exclude other recoverable damages, thereby allowing other forms of relief as may be appropriate under applicable law. As a result, the district court reversed the trial court's final judgment with respect to its denial of recovery of noneconomic damages under the FPWA and remanded the case for a trial on plaintiff's noneconomic compensatory damages. Iglesias v. City of Hialeah, 44 Fla. L. Weekly D1896 (Fla. 3d DCA July 24, 2019). Criminal Law – Search and Seizure – Search of vehicle occupants’ pouch officers ordered to be left in vehicle following traffic stop was permissible where the smell of marijuana provided officers with probable cause. The district court reversed an order granting a motion to suppress where officers searched a passenger’s pouch during a traffic stop where the officers smelled marijuana and a drug dog alerted to the pouch. The subject vehicle was stopped for a traffic infraction. Upon approaching the vehicle, the officers detected the odor of both fresh and burnt marijuana emanating from inside the vehicle. The smell of marijuana alone was sufficient to give the officers the requisite probable cause to search both the vehicle and its occupants. Accordingly, whether the pouch remained on the defendant's person or inside the vehicle was immaterial as the officers had probable cause to search it either way. State v. Tigner, 44 Fla. L. Weekly D1914 (Fla. 4th DCA July 24, 2019). Municipal Law – Negligence – Sovereign Immunity – Residents who lived in vicinity of city's former incinerator-wastewater treatment plant brought action against city for illegal discharge of hazardous substances, negligence and inverse condemnation. The district court found that city was not entitled to sovereign immunity on plaintiff’s medical monitoring claim where, although claim was brought in equity and no sovereign immunity exemption exists for equity claims, the claim is grounded in negligence, and thus the city is not entitled to sovereign immunity. The district court also concluded that the trial court’s ruling on sovereign immunity was not brought in a timely manner for appellate review. The trial court's ruling in 2012 was prior to the 2014 amendment adding a denial of sovereign immunity as a matter of law to rule 9.130. However, the city had an available remedy for interlocutory review. Prior to the rule amendment, a nonfinal order denying a claim of immunity from suit could be reviewed by certiorari. The city did not seek certiorari review in a timely manner but can seek review following the final order in this case. The district court also concluded that a continuing trespass can ripen to a constitutional taking and that the city was not immune from the inverse condemnation claim. The district court stated that the sufficiency of a takings claim is not reviewable by nonfinal appeal. City of Fort Lauderdale v. Hinton, 44 Fla. L. Weekly D1915 (Fla. 4th DCA July 24, 2019). Criminal Law – Search and Seizure – Investigatory Stop – Consensual Encounter – Defendant’s encounter with police was not consensual where officer ordered individuals to stop multiple times and testified that the individuals were detained. The district court reversed a trial court order denying a motion to suppress where an officer ordered an individual to stop finding that the stop was not a consensual encounter. What otherwise might have been a consensual citizen encounter becomes an investigatory stop once an officer shows authority in a manner that restrains the defendant's freedom of movement such that a reasonable person would feel compelled to comply. The individuals did not stop when first ordered to do so by the officer; in fact, the defendant loudly announced that he did not have to stop. The group only stopped after the second order from the officer, whose specific testimony was that he gave the teens a lawful order to stop and detained them. The district court opined that because the only basis offered by the trial court for its order denying the motion to suppress was its finding that this was a consensual encounter, it was compelled to reverse, as this was not a consensual encounter. N.J. v. State, 44 Fla. L. Weekly D1928 (Fla. 5th DCA July 26, 2019). Criminal Law – Search and Seizure – Expectation of Privacy – Protective Sweep – Search of defendant’s hotel room was improper where defendant was arrested outside of the hotel room in the hallway. The district court concluded that the search of defendant’s hotel room was unlawful where defendant was arrested outside of the hotel room in the hallway. The district court concluded that defendant had a reasonable expectation of privacy in his hotel room. The district court also opined that exigent circumstances were not present because the purpose for which the officers went to the hotel was accomplished when they observed another occupant's movement and searched the hotel, the defendant was in custody, and defendant posed no threat or harm to the officers. Finally, the district court rejected the contention that the search was proper as a protective sweep because the law enforcement officers lacked a reasonable, articulable suspicion that entry into the hotel room was necessary for officer safety or preservation of evidence. State v. M.B.W., 44 Fla. L. Weekly D1954 (Fla. 2d DCA July 31, 2019). Criminal Law – Search and Seizure – Standing – Defendant who was not the authorized driver of a rental car, pursuant to the rental agreement, had a reasonable expectation of privacy in the rental car and thus standing where he was in lawful possession and control of the rental car. The Second DCA concluded that a defendant who was not the authorized driver of a rental car, pursuant to the rental agreement, had a reasonable expectation of privacy in the rental car and thus standing where he was in lawful possession and control of the rental car. The district court reversed and remanded for a new hearing on the issue. The district court also addressed questioning by the prosecutor and a comment in closing argument regarding defendant’s failure to call witnesses. The district court concluded that the line of questioning by the prosecutor and the comment during closing arguments were improper because they suggested to the jury that defendant had an obligation to present evidence when he did not. The district court also commented on the prosecutor’s comments stating that a police officer would not make up a lie and sacrifice their career by perjuring themselves. The district court stated that it was an inappropriate attempt to persuade the jury that the police officer's testimony should be believed simply because he or she is a police officer and improperly suggested that police officers would not testify falsely because they have too much at stake. Jeansimon v. State, 44 Fla. L. Weekly D1959 (Fla. 2d DCA July 31, 2019). Criminal Law – Search and Seizure – Search Warrant – Search of defendant’s vehicle was lawful where warrant authorized officers to enter and search the said residence, curtilage, outbuildings, conveyances and persons located on said curtilage for items and contraband. The Fourth DCA affirmed the denial of the motion to suppress because the district court found that the search warrant in this case specifically authorized the search of any vehicles located on the property. The district court found this search to be reasonable because it was specifically authorized by a judicial officer. The district court did reverse and remand defendant’s sentence for a new sentencing hearing because the trial court improperly considered a subsequent arrest without conviction during sentencing for the primary offense. Price v. State, 44 Fla. L. Weekly D2027 (Fla. 4th DCA Aug. 7, 2019). Public Records Request – Security Plan Exemption – Good Cause – Newspaper extinguished claim that good-cause exception to security-plan exemption applied where newspaper advised trial court that they no longer wanted the recordings because recordings were no longer newsworthy. The First DCA concluded that the good-cause exception to the security-plan public records exemption did not apply where the requesting party advised the trial court that it was no longer seeking the recordings because the recordings were no longer newsworthy. The district court concluded that the trial court’s order compelling production of the records was an abuse of discretion where the requesting party disavowed the request. Regardless of whether the newspaper’s previously offered reasons for disclosure met the statutory standard, their contention that it no longer wanted the videos because they were no longer newsworthy means that they failed to show good cause sufficient to invoke the exception to exemption. Thus, the final order’s finding of good cause was unreasonable. Florida Dep't of Corr. v. Miami Herald Media Co., 44 Fla. L. Weekly D2050 (Fla. 1st DCA Aug. 9, 2019). Public Records – Jail Visitation Logs – Criminal Law – Detainee who was in jail awaiting trial on murder charges was not entitled to protective order to prevent disclosure of jail visitation logs as the logs were public records subject to disclosure. The Fourth DCA held that jail visitation logs were public records subject to disclosure even where such logs would reveal criminal defendant’s mental health experts retained in connection with his defense. The district court concluded that petitioner has satisfied the jurisdictional threshold of a showing of irreparable harm when he contends that revealing the names of experts who may consult or interview him while he is in jail would allow anyone to find information regarding the expert on the internet. Then, understanding the expert's area of expertise would provide a window into the attorney's defense strategy, thus invading attorney-client privilege and work product, and preventing him from receiving a fair trial. The court concluded that the Florida Constitution and the Public Records Act do not authorize redacting the names of the experts visiting petitioner in jail. If public policy demanded that these be kept confidential, it is for the Legislature to provide an exemption by statute. This is true even when judicially created privileges are implicated. Cruz v. State, 44 Fla. L. Weekly D2076 (Fla. 4th DCA Aug. 14, 2019). Municipal Ordinance – Preemption – Home Rule – City ordinance prohibiting food service providers and stores from selling or using expanded polystyrene containers was preempted by state law. The Third DCA held that city ordinance prohibiting the use of polystyrene containers was expressly preempted by state law. The district court concluded that statutes grandfather provision date in. Section 500.90 does not impermissibly single out the city or county, even though the city was the first municipality and regulate polystyrene after this date. The district court also concluded that no violation of the nondelegation doctrine occurred because plain text of statute provided that regulation of polystyrene products was preempted to the department, and department's rulemaking authority stemmed from separate unchallenged rulemaking section. As to whether the statute was arbitrary and capricious, the district court stated that it was not arbitrary and capricious because the only classification scheme found in Section 500.90 applies to ordinances – those enacted before and those enacted after January 1, 2016 – there is no classification of any governmental entities. Finally, the district court concluded that the city ordinance was expressly preempted. The district court found that the statutes at issue are unambiguous and that they expressly preempt the city's ordinance. Section 403.708(9) preempts regulatory control over “[t]he packaging of products manufactured or sold in the state ... .” The plain text encompasses all types of packaging, including polystyrene. Similarly, Section 403.7033 prohibits local governments from regulating “auxiliary containers.” Again, the “polystyrene containers” regulated by the city's ordinance are a type of “auxiliary container.” Finally, Section 500.90 specifically preempts the regulation of “polystyrene products.” In all three instances, the district court found the language clear and unambiguous. Florida Retail Fed'n, Inc. v. City of Coral Gables, 44 Fla. L. Weekly D2089 (Fla. 3d DCA Aug. 14, 2019). Municipal Law – Development – Marina owner who brought fraud and negligent misrepresentation action against city and its employee over their handling of owner's request for city approval to redevelop real property that was subsequently transferred did not lack standing as a matter of law to bring claim. The Second DCA held marina owner who brought fraud and negligent misrepresentation action against city and its employee over their handling of owner's request for city approval to redevelop real property did not lack standing as a matter of law to bring claim. The district court first concluded that, as to the fraud and negligent misrepresentation claim against the individual defendant, the continued ownership of the property was not necessary to pursue these claims. The district court concluded that the claims for declaratory relief and mandamus could continue because an affidavit established that the current party was authorized to act on behalf of the party with actual interest. As a result, the district court concluded that it was not evident as a matter of law that plaintiff lacked standing. Pirate's Treasure, Inc. v. City of Dunedin, 44 Fla. L. Weekly D2111 (Fla. 2d DCA Aug. 16, 2019). Municipal Law – Injunction – In action brought by former police officer challenging his termination, trial court’s granting of motion to stay the proceedings and to permit officer to bring three attorneys constituted a temporary injunction and standards required for such an injunction were not met. The Third DCA reversed a trial court order that stayed proceedings and permitted the police officer to attend the hearing with three attorneys because such an order constituted a temporary injunction. The officer requested a departmental disciplinary review board hearing. This is an administrative proceeding within the police department that is voluntary and non-binding and intended to be non-legal in nature. It allows a panel within the department to review the reprimand and make a recommendation and does not allow for attorney representation. The officer arrived at the hearing accompanied by three attorneys, but the city would only allow one attorney. He refused to attend the hearing, and it went on without him. The officer’s attorney ultimately called the judicial assistant in his related Section 112.534 case and made an emergency motion to stay the administrative proceeding, without giving the city the opportunity to respond. The court stayed the administrative proceeding and ordered that the officer be allowed to bring all counsel to the hearing. The Third DCA stated that any powers the trial court might exercise in this regard [staying the proceedings and allowing all counsel to attend the hearing] can stem only from its judicial power to issue writs or injunctions. Similarly, the part of the order that directed the city to allow private attorneys to attend inter-departmental hearings contrary to the city's procedures amounts to an injunction. The Third DCA then held that temporary injunctions are extraordinary remedies and the trial court did not meet the strict requirements that govern their issuance because the movant provided no adequate notice; no written motion; no specific supporting facts; and no verified pleading, affidavit or evidentiary basis; and the trial court did not consider the necessary factors. City of Miami v. Santos, 44 Fla. L. Weekly D2111 (Fla. 2d DCA Aug. 16, 2019). Contracts – Supervisory Control – A supervising architect owes a duty of care to a contractor hired by the county for an airport improvement project where the architect has sufficient supervisory duties over, and a close nexus with, contractor. The Fourth DCA held that a supervising architect owes a duty of care to a contractor hired by the county for an airport improvement project where the architect has sufficient supervisory duties over, and a close nexus with, contractor. In this case, the architect had contracts with the county, and testimony revealed that the architect effectively controlled the project and the contractor's fate. The architect was broadly responsible for administration of the county/contractor contract and sometimes acted as the county's representative. The architect was also responsible for on-site observational duties, which were later used to certify payment. The court held that a contractor is an incidental beneficiary absent clear intent manifested in the owner-architect contract to the contrary. Thus, the Fourth DCA vacated the summary judgment order in favor of the architect. Grace & Naeem Uddin, Inc. v. Singer Architects, Inc., 44 Fla. L. Weekly D2198 (Fla. 4th DCA Aug. 28, 2019). Education – Charter School – Funding – Statutory provisions requiring distribution of capital millage revenue and federal funds to charter schools were permissible. The First DCA held that statutory provisions requiring distribution of capital millage revenue to charter schools were permissible exercises of legislature supervisory powers and provisions requiring distribution of federal funds to charter schools were permissible exercises of the constitutional responsibility to ensure adequate education. The First DCA opined that the use of local taxes to fund charter schools does not, as the school boards assert, convert or transform those local taxes into something else because they are still being spent on a local priority. The First DCA also concluded that the school boards lacked standing on all the issues but the capital millage and federal funding issues because of the public official standing doctrine. Sch. Bd. of Collier County v. Florida Dep't of Educ., 44 Fla. L. Weekly D2210 (Fla. 1st DCA Aug. 29, 2019). Florida Election Code – Local Election – Section 100.141 dealing with notice and publication of requirements do not apply to locally called special elections. An individual sought mandamus and declaratory relief to force the county to comply with the notice and publication requirements relating to elections found in Section 100.141. The First DCA held that the notice and publication requirements of Section 100.141 do not apply to locally called special elections. The court stated the context clearly indicates that “special election” in Section 100.l41 does not refer to locally called, discretionary special elections. While the Florida Election Code's definition of “special election” is broad enough to include the local election at issue in this case, this general definition does not apply “when the context clearly indicates otherwise.” In context, Section 100.l41(3) only applies when the governor and department of state are involved in the election process. The court further stated that the omission of any publication requirement in Section 100.151, which is specifically targeted at local elections, indicates that the Florida Election Code does not require notice of the qualifying period for local elections. Taylor v. Hogan, 44 Fla. L. Weekly D2215 (Fla. 1st DCA Aug. 29, 2019). Florida Constitution – Land Acquisition Trust Fund – Spending of the Land Acquisition Trust Fund (LATF) is not restricted to use on land purchased by the State of Florida after 2015. The First DCA held that spending of the LATF revenues on certain appropriations relating to lands purchased prior to 2015 were not unconstitutional. Environmental groups challenged appropriations of revenue from the LATF to properties purchased prior to the LATF’s enactment. The First DCA concluded that the text of the LATF does not plainly limit the improvement of property to those properties only recently acquired. Instead, the plain words of the subsection, as well as the placement of the only colon in subsection (b), indicate that acquisition and improvement are separate but coequal activities for LATF revenue. Oliva v. Florida Wildlife Fed'n, Inc., 44 Fla. L. Weekly D2268 (Fla. 1st DCA Sept. 9, 2019). Municipal Law – Zoning – Second-Tier Certiorari – Circuit court departed from the essential requirements of law when it granted store’s motion to dismiss city’s appeal regarding whether a business was a nonconforming use. The Third DCA held that the circuit court, in its appellate capacity, departed from the essential requirements of law when it dismissed an appeal from its board of adjustment decision finding a business to be operating in a legal nonconforming use. The circuit court erred by failing to determine whether the city was afforded procedural due process, whether the essential requirements of law were observed and whether the board of adjustment's findings were supported by substantial competent evidence. Rather, the appellate division of the circuit court simply dismissed the petition. The Third DCA did not address the merits; instead, under the appropriate standard of review, it quashed the unelaborated dismissal order, so that the circuit court appellate division can apply the three-prong standard of review as directed by the Florida Supreme Court. City of Miami Beach v. Beach Blitz, Co., 44 Fla. L. Weekly D2281 (Fla. 3d DCA Sept. 11, 2019). Ad Valorem Taxation – Homestead Exemption – Homeowners were not entitled to homestead property exemption because they failed to establish that they had maintained permanent residence on the property during the year for which they claimed the homestead exemption. The Second DCA held that homeowners were not entitled to homestead exemption for failure to establish that they had maintained permanent residency even where they manifested their intent to establish residence on the subject property by changing their licenses and voter registration cards and abandoning their prior homestead. The district court found that the homeowners never maintained “residence” on the property because the structure had not yet been built. The district court ultimately held that, based on the plain and ordinary meaning of the constitutional provision providing the homestead exemption, to “maintain” “the permanent residence” on a piece of property, a taxpayer must preserve and continue in possession of a dwelling that the taxpayer physically occupies as a home and intends to return to whenever absent. The district court concluded further that, based on the plain and ordinary meaning of the operative constitutional provision, the homeowners were not entitled to a homestead exemption for their residential property for tax year 2015 because they did not maintain their permanent residence on the property until June 11, 2015, the date that they moved onto the subject property and the first time they physically occupied a house on that property. Baldwin v. Henriquez, 44 Fla. L. Weekly D2311 (Fla. 2d DCA Sept. 13, 2019). Ad Valorem Taxation – Homestead Exemption – Tax Lien – Homeowners improperly received homestead exemption where, even though they were permanent residents in Florida, were receiving a tax exemption in Ohio for permanent residency even though they did not intend on receiving such benefit in Ohio. The Second DCA affirmed a lower court decision finding that Florida homeowners were not entitled to homestead exemption and owed back taxes, even though the homeowners were Florida residents but received a permanent residence tax exemption in Ohio unintentionally. The Second DCA found the homeowners to be in violation of Section 196.031(5) which states “[a] person who is receiving or claiming the benefit of an ad valorem tax exemption or a tax credit in another state where permanent residency is required as a basis for the granting of that ad valorem tax exemption or tax credit is not entitled to the homestead exemption provided by this section.” The plain language of the statute controls even where it is undisputed that the homeowners did not intend that their home in Ohio serve as their permanent residence, that during the time they owned that property they were permanent residents of Florida receiving a homestead exemption on property in this state, and that through a third-party's error they received the benefit of a permanent residency-based tax exemption on their home in Ohio for several years. The Second DCA also upheld the lien and sanction against the homeowners pursuant to Section 196.161 finding that the sanctions still applied pursuant to the plain language even where the homeowners were permanent residents of Florida. Fitts v. Furst, 44 Fla. L. Weekly D2314 (Fla. 2d DCA Sept. 13, 2019). Ad Valorem Taxation – Homestead Exemption – Tax Lien – Homeowner improperly received homestead exemption in Florida while he was simultaneously receiving the benefit of a tax exemption in Wisconsin based upon permanent residency there in violation of Section 196.031(5). The Second DCA affirmed a lower court decision finding that a violation of Section 196.031(5) occurred where homeowner received Florida homestead exemption while simultaneously receiving the benefit of a tax exemption in Wisconsin based upon permanent residency there. The Second DCA adopted the reasoning set forth in Fitts v. Furst, 44 Fla. L. Weekly D2314 (Fla. 2d DCA Sept. 13, 2019) found directly above. Brielmaier v. Furst, 44 Fla. L. Weekly D2318 (Fla. 2d DCA Sept. 13, 2019). Contracts – Pension – Sovereign Immunity – Retirement boards were entitled to sovereign immunity where alleged breach of contract pursuant to the pension ordinance does not impose the express contractual obligations plaintiffs alleged were breached. The Third DCA held that retirement boards were entitled to sovereign immunity where alleged breach of contract pursuant to the pension ordinance does not impose the express contractual obligations plaintiffs alleged were breached. The plaintiffs alleged that the pension ordinance imposed a contractual duty to give accurate advice regarding the financial urgency ordinance to pension beneficiaries. The district court expressed reluctance about applying a contractual duty to situations where, under the auspices of ordinances requiring general supervision, municipal employees routinely provide advice to their colleagues and the public without meaning to waive sovereign immunity, even when the advice is mistaken. The district courted concluded that the alleged poor advice given by the employees to the plaintiffs do not constitute a breach of any express contractual duty imposed on the defendants by the ordinances. Thus, the plaintiffs have not stated causes of action for breach of contract for which the defendants have waived sovereign immunity. City of Miami Firefighters' & Police Officers' Ret. Tr. & Plan v. Castro, 44 Fla. L. Weekly D2343 (Fla. 3d DCA Sept. 18, 2019). Florida Sunshine Law – Public Meetings – Mediation communications disclosed by a governmental attorney during a shade meeting are permanently exempt from public records production. The Fourth DCA held mediation communications disclosed by a governmental attorney during a “shade” meeting are to be redacted from the transcript of the shade meeting when it becomes a public record. Plaintiffs alleged that Section 286.011(8) does not contain an explicit exception for mediation communications and that there is no provision of Chapter 119, Florida's Public Records Act, which permanently exempts the disclosure of the shade meeting transcript. The district court first concluded that mediation communications in written form are exempt from public disclosure under Chapter 119. The district court further concluded that this mediation exemption is permanent. However, the district court did remand the matter with instructions to the lower court to perform an in camera review to determine if the mediation aspects of the transcript can be redacted and therefore allow release of the shade transcript. Everglades Law Ctr., Inc. v. S. Florida Water Mgmt. Dist., 44 Fla. L. Weekly D2356 (Fla. 4th DCA Sept. 18, 2019). County – Budget – Sheriff – Sheriff had unilateral authority to transfer budgeted funds between objects without approval from board of county commissioners. The First DCA held that the sheriff had unilateral authority to transfer budgeted funds between objects without approval from board of county commissioners. The district court interpreted Section 30.53 which explicitly preserves the sheriff’s power “concerning the purchase of supplies and equipment, selection of personnel, and the hiring, firing, and setting of salaries of such personnel” as a broad preservation of all powers necessary for the sheriff to carry out the duties and responsibilities of her office, which necessarily must include authority over her budget and office's expenditures. The district court additionally found that there is no statutory requirement that the sheriff seek board approval prior to transferring funds between objects, unless such officer is in a lame duck period. Alachua County v. Darnell, 44 Fla. L. Weekly D2356 (Fla. 1st DCA Sept. 20, 2019). Criminal Law – Search and Seizure – Driver was required to stop at the stop line and cross-walk prior to turning right on red, thus driver was within municipal limits and officer had authority to make the traffic stop; and driver abandoned argument as to the legality of the warrantless search of his vehicle. The Fifth DCA held that a driver who took a right turn on red onto a street outside of the municipality was within the municipality when he committed the alleged infraction because he was required to stop at the crosswalk and stop line prior to entering into the intersection. However, the court did conclude that the trial court’s finding that the warrantless search of the vehicle was permitted search incident to arrest was improper because there would have been no physical evidence in the vehicle of the crime of fleeing and eluding. As to the trial court’s second rational that the warrantless search was permitted under the automobile exception, the district court did not address this exception, as the driver did not address this trial court finding and thus abandoned argument relating to this issue. As a result, the district court affirmed the denial of the driver’s motion to suppress. Jones v. State, 44 Fla. L. Weekly D2378 (Fla. 5th DCA Sept. 20, 2019). Criminal Law – Search and Seizure – Officer had a particularized and objective basis for suspecting a driver was unlawfully operating his automobile under the influence of alcohol or narcotics and was justified in conducting an investigatory stop where the passed-out driver was blocking the entrance to a gated community. The Second DCA held that an officer had a particularized and objective basis for suspecting a driver was unlawfully operating his automobile under the influence of alcohol or narcotics and was justified in conducting an investigatory stop where the passed-out driver was blocking the entrance to a gated community. The court concluded that an objective basis existed for the stop because it was shortly before midnight when the officer observed the driver's prolonged presence at the entry box with his car engine running and brake lights on and his subsequent failure to respond when a second vehicle whose path he was blocking repeatedly flashed its lights and honked its horn. Further, when the officer approached the vehicle, he heard the engine slowly revving on and off as if the accelerator was being depressed and then released, and then he saw the driver “passed out” behind the steering wheel; and despite the open car window, the officer was initially unable to wake the driver. State v. Welch, 44 Fla. L. Weekly D2382 (Fla. 2d DCA Sept. 20, 2019). Section 3. Recent Decisions of the U.S. Supreme Court. None Reported. Section 4. Recent Decisions of the U.S. Court of Appeals, Eleventh Circuit. First Amendment – Religion – Establishment Clause – County may allow sectarian prayer to start legislative sessions, but it must not employ discriminatory practices in the selection process of the volunteer invocation contributors. Plaintiff alleged that invocations given before board meetings violated the First and 14th Amendments, as well as the Florida Constitution. The circuit court framed its analysis with the precedent that invocations to open local government proceedings are appropriate but may not be exploited to proselytize or advance any one, or to disparage any other, faith or belief. To determine if such an evocation exceeds these limits the circuit court determines whether the opportunity has been exploited by applying a three-factor test that considers the identity of the invocation speakers, the process by which they are selected and the nature of the prayers they deliver. The circuit court concluded that the county has selected invocation speakers in a way that favors certain monotheistic religions and categorically excludes from consideration other religions solely based on their belief systems. Because some invocation givers were rejected based squarely on the nature of the religious beliefs, the county acted improperly. The county may not categorically exclude from consideration speakers from a religion simply because they do not like the nature of its beliefs. Williamson v. Brevard County, 27 Fla. L. Weekly Fed. C2143 (11th Cir. July 8, 2019); Williamson v. Brevard County, 928 F. 3d 1296 (11th Cir. 2019). Civil Rights – Law Enforcement – Excessive Force – Officer who shot child while attempting to shoot family dog was entitled to qualified immunity. The Eleventh Circuit reversed the district court’s denial of a motion to dismiss on the basis of qualified immunity where a law enforcement officer shot a child while attempting to shoot a family dog. An attempt to apprehend a criminal suspect spilled over into plaintiff’s yard that had one adult, six minor children and a dog. Officers ordered all of the individuals to the ground, and when a dog approached the situation, an officer fired at the dog. The shot missed the dog and struck one of the minor children. Plaintiff sued the officer individually and on behalf of her minor child for excessive force. The circuit initially concluded that the minor child, as an innocent bystander at the site of an arrest, who was ordered to the ground by law enforcement with guns drawn, was seized under the Fourth Amendment. However, the circuit court concluded that a clearly established right was not violated. Qualified immunity analysis requires a clearly established right to be defined with specificity, not a general finding that excessive force is a clearly established right. The circuit court concluded that the officer was entitled to qualified immunity because, at the time of the incident giving rise to this case, there was no clearly established law making it apparent to any reasonable officer that firing at the dog and accidentally shooting a minor would violate the Fourth Amendment. Corbitt v. Vickers, 27 Fla. L. Weekly Fed. C2166 (11th Cir. July 10, 2019); Corbitt v. Vickers, 929 F. 3d 1304 (11th Cir. 2019). Civil Rights – Red Light Camera – Local Ordinance – Motorists who had received citations challenged enforcement scheme and penalties of red-light camera citations by filing Section 1983 action against city had standing but did not sufficiently allege a violation of their constitutional rights. Circuit court vacated order dismissing plaintiffs’ complaint for lack of standing and remanded the action to the district court for further proceedings. City adopted an ordinance that permitted the installation and operation of cameras to enforce traffic-control-device violations at certain intersections through civil penalties. The circuit opined that because plaintiffs received a civil penalty under the ordinance, and because they challenge the constitutionality of that ordinance as a whole, they have standing to bring their damages claims. But plaintiffs did not have standing to seek injunctive relief as they failed to plead facts sufficient to show a likelihood of future harm. The circuit court concluded that the punishment was civil rather than criminal because it stated as such and served the non-criminal interest of public safety. As a result of providing a civil punishment, plaintiffs’ claims that the ordinance imposed a criminal penalty without sufficient Fifth and Sixth Amendment protections must fail. Plaintiffs’ claim that their First Amendment rights have been violated by being unable to petition the courts for redress must also fail. The ordinance itself allows for the result of the administrative hearing to be appealed to the circuit court in the county. The circuit court also concluded that the ordinance did not violate substantive or procedural due process rights because (1) plaintiffs fail to allege that the ordinance violated their fundamental rights, and because the ordinance is rationally related to a legitimate government purpose of public safety; and (2) the review procedures provided in the ordinance are constitutionally sufficient. Worthy v. City of Phenix City, Alabama, 27 Fla. L. Weekly Fed. C2179 (11th Cir. July 18, 2019). Housing – Fair Housing Act – Discrimination – City lacked standing to bring suit against lender alleging that, through practices of redlining and reverse redlining, it had engaged in discriminatory or predatory lending in violation of the Fair Housing Act. The Eleventh Circuit concluded that city lacked standing to bring suit against lender alleging that, through practices of redlining and reverse redlining, it had engaged in discriminatory or predatory lending in violation of the Fair Housing Act. The circuit court opined that the city had standing so long as one of the loans challenged as discriminatory had caused or would cause city to suffer a de facto injury redressable by a favorable decision. However, city did not have standing because it did not allege that it received loans from lender, did not provide evidence of single delinquent loan identified in expert's report and only speculated that certain loans would likely go into foreclosure. This did not establish a certainly impending risk that city would lose property-tax revenues or be forced to increase municipal spending to remediate blight. The circuit court also concluded that that the summary judgment standard of standing was appropriate because discovery had occurred, there was no outstanding discovery, and the city did not advise the district court that it needed further discovery. City of Miami Gardens v. Wells Fargo & Co., 28 Fla. L. Weekly Fed. C57 (11th Cir. July 30, 2019). City of Miami Gardens v. Wells Fargo & Co., 931 F.3d 1274 (11th Cir. 2019). Criminal Law – Deprivation of Rights – Officers who punched and kicked suspects after a high-speed chase used excessive force. The Eleventh Circuit found that an officer used excessive force where the officer does not dispute that he repeatedly struck, kicked and twice used a Taser against the suspect, where he acknowledged that the only circumstance justifying his use of force was failure to comply with verbal commands. The circuit court found this use of force to be willful because a fellow officer testified that punching, kicking and employing a Taser against a passively resisting passing clearly violated the department’s policies on the use of force. The witness further testified that the officer had been most recently trained on the use of force five months before the incident. Where an officer’s actions so obviously violate his training on the use of force, a jury may infer that the violation was willful. The circuit court also concluded that a fellow officer obstructed justice by giving knowingly misleading statements related to the investigation. The circuit court concluded that a reasonable jury could infer the officer’s intent from the stark difference in his memory about the incident on the one hand and his inability to recall basic facts about his subordinates’ officer reports on the other. United States v. Brown, 28 Fla. L. Weekly Fed. C98 (11th Cir. Aug. 14, 2019). Tort – Negligence – Vicarious Liability – Individual who was shot five times during wellness check was able to maintain vicarious liability suit against sheriff for negligent conduct of deputies. The Eleventh Circuit affirmed a jury verdict against a sheriff for vicarious liability for the negligent conduct of his deputies during a wellness check that resulted in the individual whose wellness was to be checked being shot five times. The circuit court first addressed what law applies – state or federal – when deciding whether a district court judge properly informed the jury about the legal effect of its finding under state law. The circuit court joined the Seventh Circuit in holding that this issue is controlled by federal law as it pertains to procedure, not substance. The circuit court then held that a trial judge is not precluded from informing jurors about the legal effects of their factual findings, even where no general duty exists to do so. The circuit court concluded that defense counsel’s Golden Rule argument in closing was not improper because it was connected to an element or factor genuinely at issue in the case, or their focus on either a party’s behavior or perception of an incident. The argument went directly to the reasonableness of the plaintiff’s response to the deputies’ actions during the wellness check, which bears directly on the foreseeability of her actions. Finally, the circuit court concluded that the admission of any improper prejudicial character evidence was harmless because the questioning related to it was brief and limited to generalities and that all witnesses were asked the same questions relating to their employment and this witness was not singled out. Thus, the circuit court affirmed trial court verdict. Ermini v. Scott, 28 Fla. L. Weekly Fed. C298 (11th Cir. Sept. 10, 2019). Civil Rights – Employment Discrimination – Police detective brought action against city and city police chief, alleging that she was terminated based on her race, gender and disability in violation of § 1981. The Eleventh Circuit held that detective alleged sufficient evidence to establish a disability; summary judgment was not warranted on detective's ADA claim; summary judgment was not warranted on detective's racial discrimination claims; and city was not subject to liability under Section 1983 for assistant police chief's allegedly discriminatory decisions. The circuit court concluded that sufficient evidence existed that one could conclude that exposure to pepper spray and Taser shocks are not an essential function of a detective job and thus plaintiff made a prima facia showing of disability. Additionally, the circuit court concluded that the court cannot yet determine if plaintiff is a direct threat because the duties have not yet been established. The circuit court also concluded that that plaintiff has presented sufficient circumstantial evidence to raise an issue of material fact as to whether she was discriminated against on the basis of sex and race. Plaintiff alleged (1) the department initiated indefinite administrative leave yet a week later terminated her for being absent without leave; (2) the department gave no warning that if plaintiff exercised the option to use her accrued leave in lieu of being on unpaid status, she would be terminated upon exhausting her accrued leave; and (3) the department gave plaintiff no notice that she had to file FMLA paperwork by any specific date, nor did the department’s written FMLA policy provide any such deadline. Additionally, the circuit court found that evidence existed to show that the department’s reasons for terminating plaintiff were pretextual. Finally, the circuit court concluded that the municipality was not subject to liability, as it is a municipality and the decision to terminate was subject to a meaningful review. Lewis v. City of Union City, Georgia, 28 Fla. L. Weekly C145 (11th Cir. Aug. 15, 2019). Municipal Law – Ordinance – Tying – Electric utility brought action under Sherman Act and Clayton Act alleging that city ordinance requiring new homes or businesses in developments outside city limits to install gas appliances in order to receive water service from city constituted unlawful tying arrangement. The Eleventh Circuit held that city was not entitled to state-action immunity because city's use of its water monopoly to increase its share of energy market was not inherent, logical, or ordinary result of legislative scheme permitting city to provide water service, and thus city was not entitled to state-action immunity from liability under federal antitrust laws in action alleging that city ordinance requiring new homes or businesses in developments outside city limits to install gas appliances in order to receive water service from city constituted unlawful tying arrangement. Diverse Power, Inc. v. City of LaGrange, Georgia, 28 Fla. L. Weekly Fed. C155 (11th Cir. Aug. 20, 2019). Civil Rights – Law Enforcement – Excessive Force – Officer did not use excessive force during an arrest when he allegedly pulled arrestee’s arms too far behind her back, cinched the cuffs too tight and tugged on her fingers and arms to remove her rings. The circuit court found that probable cause was present where victim provided detailed account of battery and that officer did not use excessive force when he allegedly pulled arrestee’s arms too far behind her back, cinched the cuffs too tight and tugged on her fingers and arms to remove her rings. The circuit court determined probable cause was present because he had the victim’s 911 call identifying arrestee as her assailant and, more importantly, the officer had (twice over) victim's sworn statement in which she alleged that arrestee had “pull[ed] [her] hair” and “punch[ed] [her] in the face.” The circuit court also found that the officer did not use excessive force because, even though arrestee exhibited no meaningful flight risk, and even though her crime was relatively minor, the force employed by the officer here wasn't remotely unusual or disproportionate. Officers routinely pull arrestees' arms behind their backs, and the circuit court has repeatedly held that painful handcuffing alone doesn't constitute excessive force. Huebner v. Bradshaw, 28 Fla. L. Weekly Fed. C186 (11th Cir. Aug. 22, 2019). Section 5. Recent Decisions of the U.S. District Courts for Florida. None Reported. Section 6. Announcements. FMAA Seminar Notebooks Available Notebooks from the 2019 FMAA Seminar are available for $175 each. Notebooks from the 2018 FMAA Seminar are available for $150, and notebooks from prior years are available for $125 each. Please contact Lisa Dove at (850) 222-9684 or ldove@flcities.com to place your order. Section 7. Attorney General Opinions of Note. Number: AGO 2019-05 Date: August 16, 2019 Subject: Community development district board voting zones Are community development districts permitted to create voting zones within the district and to have an elector residing in each such zone be elected by the district’s qualified electors to the board of supervisors? If so, may the community development district take the administrative action of establishing such voting zones? There are no provisions in Chapter 190 that authorize a district to develop its own election procedures or modify the procedures set forth in Section 190.006, Florida Statutes (2018). Section 190.006(3)(a)1 only requires elected board members to be “qualified electors of the district,” whereas the procedure you propose would also require at least some of the board members to be qualified electors of a particular zone within the district, and therefore is not authorized. It is my opinion that the grant of powers in Chapter 190 does not encompass an implied administrative authority to create zones within the District and to require supervisor candidates to reside in particular zones in order to qualify for election to the Board of Supervisors. Number: AGO 2019-06 Date: August 16, 2019 Subject: Ad valorem taxation, municipal aircraft hangar leases Whether city-owned and operated hangars at the Fernandina Beach Municipal Airport are exempt from ad valorem taxation pursuant to Article VII, Section 3(a) of the Florida Constitution (2018), when spaces inside the hangars are periodically leased to private aircraft owners to store airplanes. The leasehold interests owned by Fernandina Beach and leased to private aircraft owners are exempt from ad valorem taxation under Section 196.199(2)(a), Florida Statutes (2018), so long as the lessees are using the leaseholds for a noncommercial aviation or airport purpose or operation with no engagement in for-profit activity. Number: AGO 2019-07 Date: August 16, 2019 Subject: Vacation rentals, municipalities, grandfather provision May a city change its table of permitted uses for zoning districts to allow vacation rentals within districts in which they were not allowed under the city’s pre-2011 ordinance and still preserve the “grandfathered” status of its pre-2011 ordinance under Section 509.032(7)(b), Florida Statutes (2018)? Amending an ordinance that was enacted prior to June 1, 2011, will not invalidate the grandfathering protection for those provisions that are reenacted, but new provisions would be preempted if they revise such language in a manner that would regulate the duration or frequency of rental of vacation rentals, even when such regulation would be considered “less restrictive” than the prior local law. Number: AGO 2019-08 Date: August 16, 2019 Subject: Public records, cybersecurity testing Does Chapter 119 preclude “an agency covered by that chapter” from engaging a “vendor to conduct penetration testing of the agency’s electronic data storage systems for the purpose of detecting and remedying vulnerabilities” where such testing would potentially allow the vendor “to have access to information that is exempt from disclosure under Sections 119.071(4)(d)2.a & d, Florida Statutes (2018), and confidential under Section 119.071(4)(a)l., Florida Statutes” (pertaining to social security numbers)? If the trustees determine that the vendor penetration testing will be “for the purpose of the administration of a pension fund” within the meaning of Section 119.071(5), then it appears that any incidental disclosure to the cybersecurity vendor conducting penetration testing under a confidentiality and non-disclosure agreement would not violate Chapter 119, Florida Statutes. Additionally, potential access to or incidental release of exempt information about law enforcement personnel and firefighters to a vendor under a confidentiality agreement, for the purpose of ascertaining and ensuring its cybersecurity, would not appear to be inconsistent with the purpose underlying the exemption (i.e., ensuring the safety of such personnel), if the trustees determine there is a “substantial policy need” to undertake the vendor penetration testing (as ultimately proposed to be implemented). Number: AGO 2019-09 Date: August 16, 2019 Subject: Special district, absentee voting Does Chapter 298, Florida Statutes or general Florida law authorize or otherwise permit the use of absentee ballots by landowners voting for seats of the district board at the annual landowners’ meeting? There is no language in the district’s charter or in the statutes that control district elections that authorizes voting by mail in district landowner elections. It is therefore my opinion that the Central County Water Control District may not permit landowners to use absentee ballots when voting for district members at the annual landowners’ meetings. Number: AGO 2019-10 Date: September 11, 2019 Subject: Audit exemption to extend discretionary sales surtax Does Section 212.055(11)(d), Florida Statutes, which exempts a county from obtaining a performance audit when voters are being asked to adopt “the same discretionary surtax” as the surtax being replaced, require only the surtax rate to be the same, or does it also require the duration of the surtax as described in the enacting ordinance and ballot question to be the same? To be exempt from the requirement of a performance audit pursuant to Section 212.055(11)(d), Florida Statutes, the proposed discretionary sales surtax being voted upon must be the same as the immediately preceding surtax in all material respects, which would include the duration of the tax if duration was included in the preceding surtax. It is therefore my opinion that a local government is exempt from obtaining a performance audit pursuant to Section 212.055(11)(d), Florida Statutes, when the discretionary sales surtax being voted upon is the same in all material respects as the prior surtax, which would encompass duration of the tax if such is included in the prior surtax. Florida Municipal Attorneys Association 301 S. 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