Town of Baldwin v. Consolidated City of Jacksonville
610 So. 2d 95 (1992)
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Rule of Law:
A quasi-municipal corporation existing within a consolidated city-county government cannot annex land that falls within the territorial boundaries of the consolidated government, as such land is considered already incorporated and state law prohibits a municipality from annexing territory within another incorporated municipality.
Facts:
- Fred Miller and A.G. Ambrose own approximately 57 acres of land in Duval County, Florida.
- The parcels of land adjoin the Town of Baldwin, which is also located within Duval County.
- The Consolidated City of Jacksonville's corporate limits are coextensive with the territorial boundaries of Duval County.
- In April and September 1990, the Town of Baldwin, at the request of Miller and Ambrose, passed ordinances to annex the two parcels of land.
Procedural Posture:
- The Consolidated City of Jacksonville filed an amended complaint in a Florida trial court against the Town of Baldwin, seeking declaratory and injunctive relief.
- Both Jacksonville and Baldwin filed motions for summary judgment.
- The trial court granted Jacksonville's motion for summary judgment, denied Baldwin's motion, and declared Baldwin's annexation ordinances unconstitutional and void ab initio.
- The Town of Baldwin, as appellant, appealed the trial court's final order to the District Court of Appeal of Florida, First District, with Jacksonville as the appellee.
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Issue:
Does a quasi-municipal corporation located within a consolidated city-county government have the authority to annex adjacent land that is also within the territorial boundaries of that consolidated city-county?
Opinions:
Majority - Shivers, J.
No, a quasi-municipal corporation like Baldwin does not have the authority to annex land already within the incorporated territory of the Consolidated City of Jacksonville. Under the Florida Constitution and the 1967 law consolidating the governments of Duval County and Jacksonville, all land within Duval County became part of a single incorporated municipal entity, the City of Jacksonville. Although Baldwin was permitted to continue existing as a 'quasi-municipal corporation' with certain municipal powers, it remains subject to general state laws. Section 171.043, Florida Statutes, prohibits any municipality from annexing land 'within the boundary of another incorporated municipality.' Since the land Baldwin attempted to annex is within Duval County, it is already part of the incorporated City of Jacksonville, and therefore cannot be annexed by Baldwin.
Analysis:
This decision clarifies the jurisdictional hierarchy and territorial limitations within a consolidated city-county government. It establishes that the formation of a consolidated government effectively incorporates all territory within its boundaries, precluding smaller, pre-existing municipalities within that territory from exercising annexation powers over adjacent land. This precedent solidifies the territorial integrity of the consolidated entity against encroachment by its constituent 'quasi-municipal' corporations. The ruling significantly impacts land use and municipal expansion in areas with two-tiered governmental structures, affirming that general state laws on annexation apply even in these unique contexts.
