Moffitt v. Willis

Supreme Court of Florida
459 So. 2d 1018 (1984)

ELI5:

Rule of Law:

Under the constitutional doctrine of separation of powers, the judiciary lacks jurisdiction to adjudicate disputes concerning the legislature's compliance with its own internal procedural rules.

Facts:

In May and June of 1981, various groups of legislators allegedly held secret, closed meetings.
The Miami Herald Publishing Company and other newspapers asserted these gatherings were legislative committee meetings.
The Florida Senate's own rules (Rule 2.13) provided that 'all committee meetings shall be open to the public.'
The Florida House of Representatives' rules (Rule 6.25) similarly provided that 'all meetings of all committees shall be open to the public at all times.'
The newspapers alleged that these secret meetings violated not only the legislature's own rules but also state statutes and the Florida and U.S. Constitutions.

Procedural Posture:

The Miami Herald Publishing Company and other newspapers sued H. Lee Moffitt, Speaker of the House, and Curtis Peterson, President of the Senate, in circuit court, seeking a declaratory judgment.
The legislative leaders (petitioners) filed a motion to dismiss the complaint for lack of subject matter jurisdiction, citing the separation of powers doctrine.
The circuit court judge, Hon. Ben C. Willis (respondent), partially denied the motion, ruling that the court had jurisdiction to hear the claims related to the U.S. and Florida Constitutions and a state statute.
The legislative leaders then petitioned the Supreme Court of Florida for a writ of prohibition to stop the circuit court from proceeding with the case.

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Issue:

Does a circuit court have subject matter jurisdiction to decide whether the Florida Legislature violated its own internal rules, a state statute, and constitutional provisions by holding secret committee meetings?

Opinions:

Majority - Justice Adkins

No. The circuit court lacks jurisdiction to proceed in this matter. The doctrine of separation of powers, embodied in the Florida Constitution, reserves to each house of the legislature the power to determine its own rules of procedure. This authority includes the power to interpret, enforce, waive, or suspend those rules. The judiciary's role is to review the final product of the legislature, such as an enacted statute, not to police the internal procedures the legislature uses to create it. The complaint here does not challenge a specific law but rather the legislature's internal activities and adherence to its own rules. To decide the case, a court would have to define what constitutes a 'legislative committee meeting,' thereby invading the legislature's exclusive rulemaking prerogative. The proper forum for addressing a violation of legislative rules is within the legislature itself, through a point of order raised by a member.

Concurring in part and dissenting in part - Chief Justice Boyd

No, but with qualification. While courts should not enforce the legislature's own internal rules, the allegation that the legislature violated a state statute presents a question that is cognizable in the courts.

Concurring in part and dissenting in part - Justice McDonald

Yes. The trial judge has jurisdiction to issue a declaratory judgment. While a court cannot rule on whether the legislature violated its own internal rules, it does have jurisdiction to determine whether the alleged secret meetings violated constitutional or statutory provisions. The trial judge correctly limited the scope of the case to these cognizable legal issues, and the case should have been allowed to proceed on those grounds.

Analysis:

This decision solidifies the principle of legislative autonomy under the separation of powers doctrine in Florida. It establishes a strong precedent that shields the internal workings and procedural compliance of the legislature from judicial oversight. The ruling creates a clear distinction between judicially reviewable 'final products' of legislation (enacted laws) and non-justiciable internal legislative processes. Consequently, this case significantly limits the ability of outside parties, including the media and the public, to use the courts to enforce transparency rules that are internal to the legislative branch, placing the responsibility for such enforcement squarely on the legislature itself.

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