Donnelly v. Hillsborough County Code Enforcement Board

District Court of Appeal of Florida·Decided September 9, 2026·No. 2D2025-3092·Published

Opinion

DISTRICT COURT OF APPEAL OF FLORIDA SECOND DISTRICT

MAUREEN C. DONNELLY,

Petitioner,

v.

HILLSBOROUGH COUNTY CODE ENFORCEMENT BOARD,

Respondent.

No. 2D2025-3092

September 9, 2026

Petition for Writ of Certiorari to the Circuit Court for the Thirteenth Judicial Circuit for Hillsborough County; sitting in its appellate capacity.

Paul T. Cardillo of Law Firm of Paul T. Cardillo, Tampa, for Petitioner.

Kenneth C. Pope, Senior Assistant County Attorney, Hillsborough County Attorney's Office, Tampa, for Respondent.

LUCAS, Chief Judge.

Maureen Donnelly seeks second-tier certiorari review of a circuit court opinion that upheld a Hillsborough County Code Enforcement Board order. For the reasons that follow, we grant the petition.

I.

The facts and legal issues here can be succinctly stated. Ms.

Donnelly's home had an in-ground swimming pool in the backyard. At some point, she decided to convert it into a koi pond. In early 2022, a county code enforcement officer informed Ms. Donnelly that her property

and her pond were in violation of the Hillsborough County Property Maintenance Code1 and issued her a citation. Pertinent here, the officer noted that the pond's fencing and water clarity did not meet the requisite standards for swimming pools under section 8-117(f) of the Code.2 That section states: "Every swimming pool shall be maintained and operated in a clean, safe and sanitary manner at all times." As is clear from its text, section 8-117(f)'s requirements extend to "swimming pools," a term that is defined in section 8-106 of the Code to be:

[A]ny structure, located in a residential area, that is intended for swimming or recreation bathing and contains or may contain water over 24 inches deep, including, but not limited to in-ground, aboveground, and on-ground swimming pools; hot tubs; and non-portable spas. Ms. Donnelly maintained that her converted koi pond wasn't a swimming pool under the Code because she had no intention of using it for swimming or recreation bathing; she wanted to raise koi fish in it. The code enforcement officers apparently didn't accept that explanation. Over the ensuing months, there was some back-and-forth between the officers and Ms. Donnelly. In notes from an October 22, 2022, visit with Ms. Donnelly, one officer observed:

The pool remains stagnant and there is Koi fish in the pool. Owner is attempting to convert pool into pond. Owner is saving money to purchase a new filtration system in the future to clear up the water. Pool is secure. The citation case went before the Hillsborough County Code Enforcement Board on October 28, 2022. During the hearing, counsel

1 See generally Hillsborough County, Fla., Code of Ordinances &

Laws Ch. 8, Art. IV (2022).

2 Ms. Donelly's property and pond were cited for alleged violations

of various provisions of the Property Maintenance Code, but the sole issue in the petition before us concerns one provision, section 8-117(f).

pressed the point that the koi pond was not a swimming pool under the Code, arguing But to put – to make someone in violation of a law that is not on the books, that she's maintained is a pond and Code is saying it's not a pond, lead us to that definition. Show us where that definition is, and we'll make sure she's in compliance with that. The Code Enforcement Board's response to counsel's argument was rather dismissive:

BOARD MEMBER: My response to that is, this is a pool.

It was designed to be a pool. It was built to be a pool. Should be maintained as a pool.

A backyard pond of this size, I have seen. And I can tell you from my experiences from the few that I have seen that the water had a filtration system that kept it clear. . . .

....

[O]ur homeowner wants to call it a pond, and we're not calling it a pond. And this is an unsanitary pool, and it needs to be treated like that. That's a violation.

The board member who later made the motion to find Ms. Donnelly's property in violation of the Property Maintenance Code began the motion with: "Stay consistent with what we've done in the past with pools and ponds, whatever, okay."

Pond, or pool, or whatever, on October 31, 2022, the Code Enforcement Board issued an Order Imposing Fine against Ms. Donnelly. There is no mention, much less discussion, of section 8-106 anywhere in that order. Nor is there any citation to any legal authority that would purport to apply the Code's swimming pool sections to ponds. Effectively, the Board ruled that Ms. Donnelly's koi pond violated code provisions applicable to swimming pools. It ordered Ms. Donnelly to correct those infractions by November 4, 2022—four days after the

order's issuance—failing which a fine of $500 per day could be imposed pursuant to section 162.09, Florida Statutes (2022).

Ms. Donnelly appealed the Board's Order to the Hillsborough County Circuit Court. The circuit court engaged with section 8-106's text and the definitional question of whether Ms. Donnelly's koi pond was a swimming pool subject to section 8-117(f). But ultimately, the court deferred to the Code Enforcement Board's interpretation of the Code. In its opinion, the circuit court held, Appellant argues that her pool does not fall under [section 8-106's] definition because it is not intended for swimming or recreation. . . . Upon review of the record, there are photographs of the pool which support Appellant's assertion that her pool is not used for swimming or recreation. In one picture, koi fish can be seen swimming near the surface of green, opaque water in the pool. Nevertheless, the CESM found that the pool was a "swimming pool," as defined in Section 8-106 . . . .

"Florida courts defer to an agency's interpretation of statutes and rules the agency is charged with implementing and enforcing, unless they are clearly erroneous or contrary to law." [Hobbs v. Dep't] of Transp., 831 So. 2d 745, 747 (Fla. 5th DCA 2002). Here, it cannot be said that the CESM's interpretation of the Code of Ordinances definition of "swimming pool" is clearly erroneous. Reasonable minds could conclude that "intended for swimming" means the structure was originally designed and constructed for that purpose. Ms. Donnelly now brings a second-tier certiorari petition before this court, seeking review of the circuit court's opinion.

II.

"[W]hen a district court considers a petition for second-tier certiorari review, the 'inquiry is limited to whether the circuit court afforded procedural due process and whether the circuit court applied the correct law,' or, as otherwise stated, departed from the essential

requirements of law." Custer Med. Ctr. v. United Auto. Ins. Co., 62 So. 3d 1086, 1092 (Fla. 2010) (quoting Haines City Cmty. Dev. v. Heggs, 658 So. 2d 523, 530 (Fla. 1995)). As we recently summarized in Ybor Properties, LLC v. City of Tampa, 431 So. 3d 1079, 1084 (Fla. 2d DCA 2026), The decision to grant or withhold relief by way of second-tier certiorari largely depends on our 'assessment of the gravity of the error and the adequacy of other relief.' Save Calusa, Inc. v. Miami-Dade County, 355 So. 3d 534, 541 (Fla. 3d DCA 2023) (quoting Custer Med. Ctr.[, 62 So. 3d at 1092]. Where the petitioner has been deprived "of the full scope of review to which it was . . . entitled" a miscarriage of justice has occurred, warranting certiorari relief. See MGM of W. Fla., LLC v. Manatee County, 406 So. 3d 351, 355 (Fla. 2d DCA 2025).

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