LTC 161-2017 Florida Retail Federation, et al v. City of Miami Beach Case No. 16-031886 CA 10M
AM
BEACH
OFFICE OF THE CITY ATTORNEY
LTC No. 161-2017
TO:
FROM:
DATE:
SUBJECT:
Mayor Philip Levine
Members of the City Commission
Raul J. Aguila, City Attorney
March 28, 2017
Florida Retail Federation, et al v. City of Miami Beach
Case No. 16-031886 CA 10
LETTER TO COMMISSION
05\ -
As you know, and as expected, the Florida Retail Federation recently sued the City in Miami -
Dade Circuit Court seeking to invalidate the City's Minimum Wage Ordinance. The Plaintiffs
argued that the City's Ordinance is preempted by a 2003 state law. The City argued in response
that the state's preemption statute conflicted with the 2004 amendment to the Florida constitution
establishing a state minimum wage and providing, among other things, that "[t]his amendment
provides for payment of a minimum wage and shall not be construed to preempt or otherwise
limit the authority of the state legislature or any other public body to adopt or enforce any other
law, regulation, requirement, policy or standard that provides for payment of higher or
supplemental wages." Article X, Section 24, Fla. Constitution, subsection (f).
The State of Florida intervened on behalf of the Plaintiffs to defend the constitutionality of the
state preemption statute. But leading Florida constitutional scholars filed an amicus brief
supporting the City's argument and opining that the state's preemption law was invalid.
On March 21, 2107, Miami -Dade Judge Peter Lopez held a hearing on the case. On March 28,
2017, the court issued an adverse decision. The court found that the preemption statute did not
conflict with the constitutional amendment, and, thus, the City's Ordinance is preempted and
unlawful.
As you know, this is only the first step in a legal battle we expect to be resolved in the Florida
Supreme Court. We will immediately appeal this adverse ruling, and request immediate review
by the Florida Supreme Court, or, in the alternative, that Florida's intermediate appellate court
expedite the case in that court.
A copy of court's order is attached.
RJA/RFR/mmm
F:\ATTO\ROSR\Florida Retail Federation, Inc\CORRESPONDENCE\2017-03-28 LTC FRF v CMB SUMMARY JUDGMENT ORDER.docx
FLORIDA RETAIL FEDERATION, INC.
A Florida not for profit corporation, THE
FLORIDA RESTAURANT AND
LODGING ASSOCIATION, a Florida, not
for profit corporation, FLORIDA
CHAMBER OF COMMERCE, INC. a
Florida not for profit corporation, CEFRA,
INC., a Florida for profit Corporation,
START AGAIN, INC., a Florida for profit
corporation and GAVIN SHAMROCK,
INC., a Florida for profit corporation.
Plaintiffs,
vs.
THE CITY OF MIAMI BEACH, a Florida
Municipality,
Defendant
IN THE CIRCUIT COURT OF THE 11TH
JUDICIAL CIRCUIT IN AND FOR
MIAMI-DADE COUNTY, FLORIDA
GENERAL JURISDICTION DIVISION
CASE NO.: 16-031886 CA 10
FlUVA]_L___MlkpLlj,QMJ. ja.01,1110TION FOR SUMMARY JUDGMENT
AND DENYING DEFENDANTS MOTION FOR SUMMARY JUDGMENT
THIS CAUSE came before the Court on March 21, 2017 on the cross-motions for summary
judgment filed by the parties. Additionally, the State of Florida having been granted intervention
has filed a response in opposition to the Defendant's motion for summary judgment. Also, Amicus
Curiae briefs have been filed by Talbot "Sandy" D'Alemberte (along with listed Law Professors)
and Main Street Alliance. This oourt uiion reviewing the file, the arguments of counsel, reviewing
the well briefed and thorough arguments of the parties, intervenor and amicus in their respective
memoranda/briefs, and otherwise being fully advised in the premises, makes the following
findings of fact and conclusions of law.
1. Background.
This lawsuit deals with interplay between Constitutional Amendment Art. X, § 24, statutory
preemption under F.S. § 218.077 and the Home Rule Amendment in connection with a June
2016 Ordinance passed by the City of Miami Beach establishing a citywide minimum
hourly wage. This lawsuit followed whereby Plaintiffs seek declaratory relief invalidating
the City's "Living Wage Ordinance". The City has answered alleging that the Ordinance
is within its Home Rule Authority and that the Preemption Statute conflicts with Florida's
Minimum Wage Constitutional Amendment Art. X, § 24 passed in 2004. The State of
Florida has intervened defending the Constitutionality of the Preemption statute. Plaintiffs
and Defendant have filed cross motions for summary judgment. Additionally, two Amicus
Curiae briefs have been filed supporting the Defendant City's position. All parties concede
that there is no genuine issue of material fact and that determination of whether the City's
Minimum Wage Ordinance is valid is a question of law to be decided by this Court.
2. Horne Rule Amendment. "
In 1968 the Florida constitution was amended to afford Municipalities broad discretion in
the managing and conducting of municipal governmental functions. Prior to the
amendment Municipalities were required to obtain special legislative acts to conduct their
affairs. Pursuant to the Amendment, "Municipalities shall have governmental, corporate
and proprietary powers to enable them to conduct municipal government, perform
municipal functions, ancl,,xenclg municipal services, and may exercise any power for
municipal purposes except as otherwise provided by law," Fl. Const., Art. VIII, § 2(b). This
constitutional provision was codified in the Municipal Home Rule Powers Act
("MHRPA"), F.S. § 166.021 affirming the broad, exercise of home rule powers as granted
by the Constitution in connection with policy making regarding local matters. However,
that is not say that this broad exercise is unlimited and Florida courts have made clear that
"municipal ordinances must yield to state statutes." Masone v. City of Aventura, 147 So.
3d 492, 494-95 (Fla. 2014; The critical phrase of article VIII, § 2(b) 'except as otherwise
provided by law' -- established the constitutional superiority of the Legislature's power
Florida Retail Federation, Inc., et. al., v. City of Miami Beach —16-031886 CA 10
Page 2 of 8
over municipal powers." City of Palm Bav v. Wells Farga Bank. N.A., 114 So. 3d 924,
928. (Fla. 2013).
3 , The Preemption Statute.
In 2003 the Florida Legislature passed Fla. Stat. § 218.077, a preemption statute that
prohibits any political subdivision of the state — such as a Municipality like the Defendant,
City of Miami Beach -- from establishing a minimum wage other than the Federal Minimum
Wage which at the time was $5.15 an hour, At the time that this statute was passed, Florida
did not have a minimum wage. In fact many political subdivisions had passed their own
versions of Living Wage Ordinances concerning the wages that the subdivision body itself
must pay, as well as any service contractors dealing with the County or municipality and
any employers receiving direct thx abatements. These practices existing before the passage
of F.S. § 218.077, (the Wage Preemption statute), were exempted under subsection 3. In
2013, F.S. 218.077(2) was amended to add the State minimum wage language as a wage
that political subdivisions could require. The legislature made no changes to the language
of prohibition contained in the 2003 version.
4, The Constitutional Amendment.
dment.
In 2004, Florida voters amended the Florida Constitution to include Article X, § 24, which
declared a statewide minimum wage floor higher than that provided for by Federal Law.
(Florida Minimum Wage Amendment), The voters approved said amendment upon being
presented with the following ballot summary:
This Amendment creates a Florida minimum wage covering all
Employees in the:state'dovered by the federal minimum wage. The
State minimum wage will start as $6.15 per hour six months after
Enactment, and thereafter . be indexed to inflation each year. It
provides for enforcement, including double damages for unpaid
wages, attorney's fees, and fines by the state, It forbids retaliation
against employees for exercising this right.
Florida Retail Federation, Ir1c, et. al., v. City of Miami Beach -16-031886 CA 10
Page3of8
In re Advisory On, to Att'y Gen, re Florida Minimum Wage Amendment, 880 So, 2d 636,
637 (Fla. 2004) (emphasis added). Subsection 24(f) of the Amendment language goes on to
provide that the amendment "shall not be construed to preempt or otherwise limit the
authority of the state legislature or any other public body to adopt or enforce any other law,
regulation, requirement, policy or standard that provides for payment of higher or
supplemental wages." Art. X, § 24(f), Fla. Const,
4. Issue.
Whether the City's minimum wage ordinance is valid in light of Fla. Stat. § 218.077, which
prohibits municipalities from establishing a minimum wage or whether the Constitutional
Amendment preempts the statute.
5. Analysis.
Summary judgment is appropriate when the pleadings and evidence on file establish that
there is no genuine issue of material fact, and the moving party is untitled to judgment as a
matter of law. F.R.C.P..1.510(c). The constitutionality of a state statute is a question of
law to be decided by the Court. Florida Dep't of Revenue v. American Bus. USA Corp.,
191 .So. 3d 906, 911 (Fla. 2016).
Florida courts do not have the authority to invalidate a statute unless it is clearly contrary
to a prohibition found in the Constitution, Abdool v. Bondi, 141 So, 3d 529, 541 (Fla,
2014), The state, meanwlr1le; hilts' Legislative capacity has particularly broad authority to
limit the municipal power of local governments under Article VIII, § 2(b) of the Florida
Constitution and its pertinent language except as otherwise provided for by law. It is
under this Constitutional authority that the Legislature has the power to enact preemption
statutes, such as F.S. §218.077, prohibiting municipalities from establishing a minimum
wage. Preemption whether Constitutional or Statutory may take different forms.
Preemption may be accoslis1l by Express preemption — that is,, by statutory provision
stating that a particular subject is preempted by law or that local ordinances on a particular
Florida Retail Federation, Inc., et. al., v. City of Miami Beach --16-031886 CA 10
Page 4 of 8
subject are precluded, Preemption by state law, however, "need not be explicit so long as
it is clear that the legislature has clearly preempted local regulation of the subject,"
Batragan_v_. City of Miami, 545 So. 2d 252, 254 (Fla. 1989). "Implied preemption is found
where the state legislative scheme of regulation is pervasive and the local legislation would
present the danger of conflict with that pervasive regulatory scheme." Sarasot Alliance
for Fair Elections, Inc, v. Browning, 28 So. 3d 880, 886 (Fla. 2010). Conflict preemption
is found in situations where concurrent state and municipal regulation is permitted because
the state has not preemptively occupied a regulatory field, however, a municipality's
concurrent legislation must not conflict with state law." City of Palm Bay v. Wells Fargo
Bank, N.A., supra. Thus, while Florida municipalities are "given broad authority to enact
ordinances under [their] municipal home rule powers, Florida courts have made clear that
"municipal ordinances must yield to state statutes." Masone v. City o#' Aventura, supra.
If municipal ordinances must "yield" to state statutes, such as §218.077, then the only way
for the City's minimum wage ordinance to be viable is if the City identifies a constitutional
provision prohibiting the State from preempting said ordinance. The City points to Article
X, § 24(f) of the Florida Constitution for that support. Article X, § 24 (f) provides:
This amendment:gha11,ipt be construed to preempt or otherwise limit
the authority of the state legislature or any other public body to adopt
or enforce any other law, regulation, requirement, policy or standard
that provides for the payment of higher or supplemental wages or
benefits, or that extends such. protections to employers or employees
not covered by this amendment.
The city reads this language as explicit authorization for municipalities to pass and enforce
minimum wage provisions higher than that set by the state or federal government. The
City further argues that the language of § 24 (b) would be rendered meaningless lithe state
is permitted to use § 218.077 to nullify minimum wage ordinances enacted at the local
level, This _ Court finds that the City reads th.e plain languago of the Amendment
erroneously,
Florida Retail Federation, Inc., et. al., v. City of Miami Beach --16-031886 CA 10
Page 5 of 8
As our Supreme Court stated in Graham v. Haridopolos, 108 So.3d 597, 603, (Fla, 2013),
"When reviewing a constitutional provisions, this Court follows principles parallel to those
of statutory interpretation, First and foremost, this Court must examine the actual language
used in the Constitution. If that language is clear, unambiguous, and addresses the matter
in issue, then it must be enforced as written. The City asserts that Article X, § 24(f)
authorizes and empowers municipalities to establish a local minimum wage. But that is
not exactly what the Amendment says. Rather, the Amendment provides that the
Amendment itself shall not be construed as preempting a municipality from establishing
a higher minimum wage — "this amendment shall not be construed to preempt or otherwise
limit the authority of the state legislature or any other public body [municipality] to adopt
or enforce [a higher minimum wage]." Art. X, § 24(f), Fla. Const.
It is not so much what the Amendment says but what the Amendment does not say. This
Amendment does not prohibit other laws, such as § 218.077, from preempting a local
minimum wage ordinance. The clear and unambiguous language of § 24(0 does not
invalidate or even reference theegislature's preemption powers recognized in Article
VIII, § 2(b) and the case law •interpreting same, nor does the amendment reference in
anyway, much less repeal, the wage preemption statute that was codified and existing at
the time. The ballot language confirms that the voters determined that the minimum wage
in the State of Florida should be $6.15. Consequently, Article X, § 24(f) and § 218.077 can
be logically read together without conflict as they pertain to preemption in different
contexts — the former indicating that the Amendment itself does not preempt a local
minimum wage, and theiatter indicating that the state does preempt local minimum wage
ordinances.
Interpreting the Amendment in this fashion does not render its language "nugatory," as
suggested by the City. A more accurate description is to say that the Amendment's
language is extraneous to the issue presented in this declaratory action. If the question in
this case were "whether the
endment prohibits a municipality from enacting a local
Florida Retail Federation, Inc., et, al., v. City of Miami Beach —16-031886 CA 10
Page 6 of 8
minimum wage," the answer would clearly be "no." But that is not the question before the
court. The question here is whether the Constitutional Amendment preempted the State
statute, that answer is also "no." Therefore, the City's minimum wage ordinance conflicts
with and violates F.S. § 218.077, a valid wage preemption statute.
6. Conclusion.
The City's wage ordinance is not valid under § 218.077, Fla. Stat., which preempts local
minimum wages. Article X, § 24(f) of the Florida Constitution set the state's minimum
wage floor. Its language did not nullify the state's wage preemption statute, which does
prohibit local minimum wage ordinances. Based on preemption principles discussed above,
because both Article X, § 24(f), and F.S. § 218,077 can be read together without conflict, §
218.077 remains in effect, and the City's wage ordinance is declared to be invalid.
WHEREFORE, for all tie foregoing reasons, it is:
OREDERED AND ADJUDGED:
1. Defendant City of Miami Beach's Motion for Summary Judgment be and in the same
is hereby DENIED.
2. Plaintiff's Motion for.Summary Judgment be and in the same is hereby GRANTED and
the City of Miami Beach Living Wage Ordinance is declared invalid.
DONE AND ORDERED In Chambers at ami -►jade County, Florida, on 03/27/17.
CIRCUIT COURT JUDGE
Florida Retail Federation, Inc., et. al., v. City of Miami Beach —16-031886 CA 10
Page 7 of 8
•
FINAL ORDERS AS TO ALL PARTIES
SRS DISPOSITION NUMBER 12
THE COURT DISMISSES THIS CASE AGAINST
ANY PARTY NOT LISTED IN THIS FINAL ORDER
OR PREVIOUS ORDER(S). THIS CASE IS CLOSED
AS TO ALL PARTIES.
Judge's Initials PRL
The parties served with this Order are indicated In the accompanying 11th Circuit email
confirmation which includes all emaiis provided by the submitter. The movant shall
IMMEDIATELY serve a true and correct copy of this Order, by mall, facsimile, email or
hand -delivery, to all parties/counsel of record for whom service Is not indicated by the
accompanying llth Circuit confirmation, and file proof of service with the Clerk of Court.
Signed original order sent electronically to the Clerk of Courts for filing In the Court file.
Cc: Charles S. Caulkins, Esq.
James C. Polldnghorn, Esq.
Donald M. Papy, Esq.
Robert F. Rosenwald, Esq.
Jonathan L. Williams, Esq.
Lauri Waldman Ross, Esq..
Richard F. Della Fera, Esq,
Florida Retail Federation, Inc., et, al, v. City of Miami Beach —16-031886 CA 10
Page 8 of 8