City of North Miami v. Florida Defenders of the Environment
481 So. 2d 1196 (1985)
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Rule of Law:
A provision in a general appropriations act that effectively amends or changes existing substantive law on subjects other than appropriations violates the Florida Constitution's single-subject rule.
Facts:
- Florida law established the Conservation and Recreation Lands Trust Fund (CARL Fund) for the state to acquire environmentally significant lands.
- Florida Statutes §§ 253.023(3) and 259.035 prescribe specific purposes and detailed procedures for selecting which lands the state may purchase using CARL Fund monies.
- The Florida Legislature enacted the 1983 General Appropriations Act.
- Item 1312A of the act appropriated $8,500,000 from the CARL Fund to the Special Acquisition Trust Fund.
- This appropriation was specifically designated for the state's purchase of a particular property known as the 'Interama Lands' from the City of North Miami, bypassing the standard statutory selection process.
Procedural Posture:
- Florida Defenders of the Environment, Inc. initiated a legal challenge to the constitutionality of appropriation Item 1312A in chapter 83-300, Laws of Florida.
- The Florida First District Court of Appeal, an intermediate appellate court, held that the appropriation item was invalid.
- The case was then brought before the Supreme Court of Florida, the state's highest court, for review of the district court's decision invalidating a state law.
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Issue:
Does a provision in a general appropriations act that directs the use of state funds for the purchase of a specific parcel of land, thereby bypassing established statutory procedures for land acquisition, violate the Florida Constitution's requirements that laws embrace a single subject and that appropriations bills contain no other subject?
Opinions:
Majority - Adkins, J.
Yes. A provision in an appropriations bill violates Article III, sections 6 and 12 of the Florida Constitution if it changes or amends existing law on subjects other than appropriations. Item 1312A is not merely an appropriation; it is a substantive directive that circumvents the established statutory scheme for selecting and purchasing conservation lands. By mandating the purchase of a specific parcel, the legislature impermissibly used an appropriations bill to enact substantive law, thereby violating the constitutional requirement that laws embrace only one subject and that appropriations bills be confined to the subject of appropriations.
Analysis:
This decision reinforces the constitutional separation between the appropriations process and substantive lawmaking in Florida. It serves as a crucial check on the legislature's power, preventing it from embedding policy changes or special interest projects within a must-pass appropriations bill, a practice known as 'logrolling.' The ruling protects the integrity of established statutory schemes by ensuring that any changes to them are made through standalone legislation, subject to proper debate and scrutiny, rather than being hidden in a budget. This precedent strengthens the single-subject rule as a vital tool for ensuring legislative transparency and accountability.
