Chiles v. CHILDREN A, B, C, D, E, AND F
589 So. 2d 260 (1991)
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Rule of Law:
The legislative branch cannot delegate its exclusive constitutional power to make and reduce appropriations to the executive branch without providing sufficient standards and guidelines to direct the executive's actions. A statute granting the executive unfettered discretion to alter legislative appropriations violates the separation of powers doctrine.
Facts:
- The Florida Legislature passed the 1991 Appropriations Act, establishing the state budget for the fiscal year.
- Subsequently, Governor Lawton Chiles determined that the state faced an estimated general revenue shortfall of $621.7 million.
- Acting under the authority of section 216.221 of the Florida Statutes, the Governor directed all state agencies to prepare revised financial plans to reduce their operating budgets.
- The Administration Commission, an executive body composed of the Governor and Cabinet, then adopted the Governor's recommendations, reducing the budgets previously established by the Legislature.
- These reductions impacted various state programs and services, including those intended to benefit appellees, six of Florida's foster children.
Procedural Posture:
- Six foster children (Children A, B, C, D, E, and F) filed a lawsuit in the Eleventh Judicial Circuit Court in Dade County, Florida (a trial court), against Governor Chiles and the Administration Commission.
- The children sought a declaratory judgment that the budget-cutting statutes were unconstitutional and an injunction to prevent their enforcement.
- The trial court ruled in favor of the children, declaring sections 216.011(1)(ll) and 216.221, Florida Statutes (1989), unconstitutional and enjoining the Commission from implementing the budget cuts.
- The Commission, as appellants, appealed the trial court's order to the Third District Court of Appeal (an intermediate appellate court).
- The Third District Court of Appeal, without ruling on the merits, certified the case to the Supreme Court of Florida as a matter of great public importance requiring immediate resolution.
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Issue:
Does a statute that grants an executive commission the broad discretionary authority to reduce budgets established by the legislature, without providing specific guidelines, violate the separation of powers doctrine under the Florida Constitution?
Opinions:
Majority - Justice Barkett
Yes. A statute granting an executive commission broad discretionary authority to reduce legislatively established budgets without specific guidelines violates the separation of powers doctrine. The Florida Constitution explicitly divides governmental power among the legislative, executive, and judicial branches and prohibits one branch from delegating its constitutionally assigned power to another. The power to appropriate state funds, which includes the power to reduce appropriations, is an exclusive legislative function. By empowering the Administration Commission to reduce appropriations with no guiding principles, section 216.221 unlawfully delegates the legislature's fundamental policymaking responsibility to the executive branch. Furthermore, section 216.011(1)(ll) is unconstitutional for defining the judicial branch as a 'state agency' subject to executive budgetary control, which violates the judiciary's status as a coequal branch of government.
Concurring - Justice Overton
I concur with the majority. The central constitutional flaw in section 216.221(2) is its grant of unlimited legislative policy-making discretion to the Governor and Cabinet. The executive's actions under this statute, such as the total elimination of funds for emergency housing for homeless families, were not minor adjustments but substantial policy decisions that effectively repealed legislative action. While this statute is unconstitutional, the legislature is not barred from creating a constitutional process for making budget adjustments that includes specific guidelines and avoids the need to reconvene for a special session.
Dissenting - Justice McDonald
No. The challenged statute does not constitute an unconstitutional delegation of legislative power. The Florida Constitution's mandate for a balanced budget imposes an obligation on all branches of government. The Governor is vested with the 'supreme executive power' and the responsibility to 'take care that the laws be faithfully executed,' which includes the balanced budget requirement. Section 216.221 provides a necessary and reasonable framework for the Governor and the Commission to fulfill this constitutional duty in the face of a revenue deficit. This statute represents a permissible exercise of shared authority between the branches to prevent the expenditure of funds that are not available, and defining the judicial branch as a state agency for budgetary purposes is permissible.
Analysis:
This landmark decision strongly reaffirms the nondelegation doctrine and the strict separation of powers under the Florida Constitution. It solidifies the principle that the legislature's 'power of the purse' is a core, non-delegable function. The ruling significantly constrains the executive branch's ability to unilaterally manage budget crises, requiring either legislative action via special session or the enactment of highly specific, guideline-driven statutes to authorize executive budget modifications. The decision also crucially protects the administrative and fiscal independence of the judicial branch, cementing its status as a coequal branch of government free from executive oversight.
