MARTIN CTY. v. Dept. of Community Affairs
2000 WL 1726948, 771 So. 2d 1268 (2000)
Premium Feature
Subscribe to Lexplug to listen to the Case Podcast.
Rule of Law:
A map or other document explicitly adopted by a local government ordinance as an amendment to its comprehensive plan is considered a substantive part of the plan, not merely supporting data, and is therefore invalid if not supported by appropriate data and analysis as required by statute.
Facts:
- In late 1996 and early 1997, Martin County experienced road overcapacity, leading to a moratorium on development in certain areas.
- In 1997, the City of Stuart began annexing parcels of real property, ultimately totaling around 1,200 acres, that were previously under Martin County's jurisdiction.
- Following the annexations, the City of Stuart initiated the process of amending its comprehensive plan to incorporate the new territories.
- As part of the amendments, the City of Stuart, via Ordinance 1628-97, adopted a 'Future Annexation Area Map' which identified approximately 8,000 additional acres of land for potential annexation through 2015.
- The ordinance explicitly stated that the map was 'adopted as amendments to the Plan.'
Procedural Posture:
- Martin County filed serial petitions with the Department of Community Affairs (DCA) to challenge amendments to the City of Stuart's comprehensive plan.
- 1000 Friends of Florida, Inc. intervened in the proceedings, siding with Martin County.
- The five cases were consolidated for a hearing before an administrative law judge (ALJ).
- The ALJ issued a recommended order largely finding the amendments to be 'in compliance' with state law.
- The DCA entered a final order that adopted the majority of the ALJ's findings and upheld the amendments.
- Martin County and 1000 Friends of Florida, Inc., as appellants, appealed the DCA's final order to the District Court of Appeal of Florida, Fourth District.
- The DCA and the City of Stuart are the appellees in the appeal.
Premium Content
Subscribe to Lexplug to view the complete brief
You're viewing a preview with Rule of Law, Facts, and Procedural Posture
Issue:
Is a 'Future Annexation Area Map,' which was explicitly adopted by ordinance as an amendment to a city's comprehensive plan, invalid for failing to be supported by appropriate data and analysis as required by section 163.3177(8), Florida Statutes?
Opinions:
Majority - Stevenson, J.
Yes, the 'Future Annexation Area Map' is invalid. A map that is explicitly adopted by ordinance as an amendment to a comprehensive plan constitutes a substantive part of that plan and is not merely data or analysis. Under § 163.3177(8), Florida Statutes, all elements of a comprehensive plan, whether mandatory or optional, must be based upon appropriate data and analysis. The City of Stuart's ordinance unequivocally identified the map as an amendment to its plan, contradicting the Department's argument that it was simply data. Because the record shows that no data or analysis was offered in support of the map's boundaries, the amendment fails to comply with statutory requirements and must be reversed.
Analysis:
This decision reinforces a key principle of Florida's growth management law: planning decisions must be based on a rational, evidence-based process. It prevents local governments from circumventing the statutory requirement for data-supported planning by simply mislabeling a substantive policy document, like a future land use map, as 'data.' The court's focus on the city's own legislative act (the ordinance) clarifies that the legal status of a document, not its title, determines the standards it must meet. This ruling ensures that future land use planning, particularly concerning annexation, is deliberate and supported by facts rather than being arbitrary or aspirational.
