Schreiner v. McKenzie Tank Lines, Inc.
432 So.2d 567, 1983 Fla. LEXIS 2359 (1983)
Rule of Law:
Article I, Section 2 of the Florida Constitution, which enumerates basic rights and prohibits deprivation of rights due to physical handicap, requires state action for its application, similar to the Fourteenth Amendment of the U.S. Constitution.
Facts:
- James Schreiner was employed as a repairman by McKenzie Tank Lines, Inc., a job that involved operating motor vehicles on the highway.
- Schreiner experienced epileptic seizures on three separate occasions during his employment.
- After his first seizure, the State of Florida revoked Schreiner's driver's license.
- Following his second seizure, Schreiner's doctor advised him to restrict his work to activities that did not require him to be off the surface of the ground.
- McKenzie Tank Lines, Inc. terminated Schreiner's employment after he suffered a third seizure while working.
Procedural Posture:
- James Schreiner initiated an action in the trial court.
- The trial court dismissed Schreiner's action.
- Schreiner appealed to the First District Court of Appeal.
- On appeal, the district court considered whether Schreiner was unconstitutionally deprived of his employment in violation of Article I, Section 2 of the Florida Constitution.
- The district court held that Article I, Section 2 requires state action and does not apply to private action, and certified a question of great public importance to the Supreme Court of Florida.
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Issue:
Does Article I, Section 2 of the Florida Constitution, which prohibits deprivation of rights due to physical handicap, require a showing of state action before an individual can seek relief under its provisions?
Opinions:
Majority - OVERTON, Justice
Yes, Article I, Section 2 of the Florida Constitution requires state action for relief to be granted under its provisions. The Court found that the framers of this constitutional provision did not intend for it to have a broader application than the related provisions of the Fourteenth Amendment to the United States Constitution, which has long been held to require state action to protect against discriminatory government conduct, not purely private conduct. The Court reviewed the transcripts from the Constitutional Revision Commission and concluded there was no intent to expand Article I, Section 2 to protect against private conduct. It rejected the petitioner's arguments based on textual differences within Article I, Section 2, and interpretations of other state constitutions, finding them unpersuasive. The Court further noted that the legislature's subsequent enactment of statutory anti-discrimination protections against private employers (sections 23.161-167) indicated the creation of new statutory rights, rather than an interpretation or implementation of Article I, Section 2. Therefore, Article I, Section 2 addresses the relationship between the people and the state, not individual invasions of individual rights.
Analysis:
This case establishes a significant precedent by clarifying that Florida's basic rights provision, Article I, Section 2, is not a shield against purely private discrimination, aligning it with federal constitutional interpretation requiring state action. This limits the direct reach of the state constitution to governmental conduct, compelling individuals seeking redress for private discrimination to rely on specific statutory protections rather than direct constitutional claims. The ruling underscores the Florida Supreme Court's commitment to interpreting constitutional provisions based on original intent and established legal principles, thereby shaping the scope of civil rights enforcement in the state.
