City of Miami v. Emilio Tomas Gonzalez

CourtDistrict Court of Appeal of Florida
DecidedJuly 31, 2025
Docket3D2025-1398
StatusPublished

This text of City of Miami v. Emilio Tomas Gonzalez (City of Miami v. Emilio Tomas Gonzalez) is published on Counsel Stack Legal Research, covering District Court of Appeal of Florida primary law. Counsel Stack provides free access to over 12 million legal documents including statutes, case law, regulations, and constitutions.

Bluebook
City of Miami v. Emilio Tomas Gonzalez, (Fla. Ct. App. 2025).

Opinion

Third District Court of Appeal State of Florida

Opinion filed July 31, 2025. ________________

No. 3D25-1398 Lower Tribunal No. 25-12463-CA-01 ________________

City of Miami, Appellant,

vs.

Emilio Tomas Gonzalez, et al., Appellees.

An Appeal from the Circuit Court for Miami-Dade County, Valerie R. Manno Schurr, Judge.

Kozyak Tropin & Throckmorton LLP, and Dwayne A. Robinson and Brandon Sadowsky; George K. Wysong III, City Attorney, and Eric J. Eves, Assistant City Attorney Supervisor, for appellant.

Lawson Huck Gonzalez, PLLC, and C. Alan Lawson (Tallahassee), Jason B. Gonzalez (Tallahassee), Paul Huck, Jr., Mathew D. Gutierrez, Anthony J. Sirven, Matthew Casbarro, and Brian M. Trujillo, for appellee Emilio Tomás González; Geraldine Bonzon-Keenan, Miami-Dade County Attorney, and Michael B. Valdes and Miguel A. Gonzalez, Assistant County Attorneys, for appellee Miami-Dade County.

Before EMAS, GORDO and LOBREE, JJ. GORDO, J.

The City of Miami (“City”) appeals a final judgment entered in favor of

Emilio Tomas Gonzalez (“Gonzalez”), which denied its emergency motion to

dismiss the complaint and granted Gonzalez’s motion for summary

judgment. We have jurisdiction. Fla. R. App. P. 9.030(b)(1)(A).

In this appeal, we are tasked with deciding whether the City’s

enactment of an ordinance (“Ordinance”) changing its general municipal

elections to even-numbered years—effectively canceling its upcoming

November 2025 election and extending the terms of its elected officials

beyond their established term limits—without submission to the voters for

approval by referendum is constitutionally impermissible. We hold the trial

court correctly found the Ordinance unconstitutional and affirm.

I.

Home Rule Amendment

In 1956, the Florida Constitution of 1885 was amended to grant the

electors of Miami-Dade County the power to control the nature and structure

of their local government through the adoption of a home rule charter. Article

VIII, section 11 of the 1885 Florida Constitution (“Home Rule Amendment”)1

1 The current version of the Florida Constitution preserves the Home Rule Amendment. See Art. VIII, § 6(e), Fla. Const.

2 provided: “[t]he electors of Dade County, Florida, are granted power to adopt,

revise, and amend from time to time a home rule charter of government for

Dade County, Florida, under which the Board of County Commissioners of

Dade County shall be the governing body.” Art. VIII, § 11(1), Fla. Const.

(1885).

The adoption of the Home Rule Amendment was prompted by the

unique and growing needs of Miami-Dade County, which, by the mid-

twentieth century, had become the most populous county in Florida and was

home to the State’s largest city. As the Florida Supreme Court observed in

Gray v. Golden, 89 So. 2d 785 (Fla. 1956), Miami-Dade County’s complexity

justified a more flexible and locally responsive form of government. The

Court recognized: “[t]hat Dade is the most populous county in the state; that

Miami in said county is the largest city in the state; that there are twenty-six

municipalities in Dade County; that said county is a great railroad,

manufacturing and commercial center; that it has one of the great harbors of

the nation; that the airborne freight and passenger traffic originating in and

passing through Dade County is national and international in scope, and that

said factors constitute Dade County one of the great metropolitan areas of

the world.” Gray, 89 So. 2d at 786.

3 The Home Rule Amendment was an elegant negotiation between the

voters of the State of Florida and the people of Miami-Dade County, in which

the State, through its Constitution, granted the County Home Rule authority

in certain limited and expressly enumerated provisions dealing with local

affairs and preserved its power to legislate in all matters of state interest as

expressed in the Constitution and the general law. Indeed, the purpose of

this Amendment “was not only to provide local self-government to the people

of Dade County with the board of county commissioners as the governing

body, but to preserve the supremacy of the legislature in all matters of state

interest as expressed in the Constitution and the general law.” Gray, 89 So.

2d at 788.

As the Florida Supreme Court continues to recognize, “the

metropolitan government of Dade County is unique in this state due to its

constitutional home rule amendment.” Metro. Dade Cnty. v. City of Miami,

396 So. 2d 144, 146 (Fla. 1980). The Home Rule Amendment “gives Dade

County numerous powers which set Dade apart from the state’s other

counties.” Id. “One such difference is Dade County’s power to enact

ordinances, when expressly authorized by the home rule amendment, which

conflict with the state constitution or with state law.” Id. (citing Art. VIII,

§ 11(5), Fla. Const. (1885)) (emphasis added).

4 Subsection (1) of the Home Rule Amendment includes ten specific

grants of authority. As to these ten matters, the Florida Supreme Court has

expressly held the Miami-Dade County Home Rule Charter governs over

general law, and “[i]n all other matters the Constitution and general laws

control.” Gray, 89 So. 2d at 791. Relevant to this appeal, Article VIII, section

11(1)(g) provides Miami-Dade County the unique ability to regulate the

formation and amendment of municipal charters.

Miami-Dade County Home Rule Charter

Acting under the above constitutional grant of authority, on May 21,

1957, the electors of Miami-Dade County adopted the Miami-Dade County

Home Rule Charter (“County Home Rule Charter”), becoming the first charter

county in Florida to exercise Home Rule powers. Consistent with the Florida

Constitution’s provision empowering it to adopt a “method by which each

municipal corporation in Dade County shall have the power to make, amend

or repeal its own charter,” Miami-Dade County prescribed such a framework

by enacting Article VI, section 6.03(A) of its Home Rule Charter.2 Art. VIII, §

11(1)(g), Fla. Const. (1885). Article VI, section 6.03(A) requires any

municipal charter amendment to be submitted to the electorate for approval:

2 Article VI, section 6.03, included in the original 1957 County Home Rule Charter, has never been amended.

5 Except as provided in Section 6.04 [for changes to municipal boundaries], any municipality in the county may adopt, amend, or revoke a charter for its own government or abolish its existence in the following manner. Its governing body shall, within 120 days after adopting a resolution or after the certification of a petition of ten percent of the qualified electors of the municipality, draft or have drafted by a method determined by municipal ordinance a proposed charter amendment, revocation, or abolition which shall be submitted to the electors of the municipalities. Unless an election occurs not less than 60 nor more than 120 days after the draft is submitted, the proposal shall be submitted at a special election within that time. The governing body shall make copies of the proposal available to the electors not less than 30 days before the election. Alternative proposals may be submitted. Each proposal approved by a majority of the electors voting on such proposal shall become effective at the time fixed in the proposal.

Art. VI, § 6.03(A), Miami-Dade County Home Rule Charter (emphasis added).

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