Natalie Nichols v. City of Miami Beach

CourtDistrict Court of Appeal of Florida
DecidedOctober 1, 2025
Docket3D2024-0649
StatusPublished

This text of Natalie Nichols v. City of Miami Beach (Natalie Nichols v. City of Miami Beach) 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
Natalie Nichols v. City of Miami Beach, (Fla. Ct. App. 2025).

Opinion

Third District Court of Appeal State of Florida

Opinion filed October 1, 2025. Not final until disposition of timely filed motion for rehearing.

________________

No. 3D24-0649 Lower Tribunal No. 18-21933-CA-01 ________________

Natalie Nichols, Appellant,

vs.

City of Miami Beach, Appellee.

An Appeal from the Circuit Court for Miami-Dade County, Thomas J. Rebull, Judge.

Valero Law PLLC, and Davied T. Valero and Amanda E. Valero- Vincent, for appellant.

Ricardo J. Dopico, City Attorney, and Robert F. Rosenwald, Jr., Chief Deputy City Attorney; Carlton Fields, P.A., and Enrique D. Arana, Scott E. Byers, and Rachel A. Oostendorp, for appellee.

Before EMAS, MILLER and LOBREE, JJ.

EMAS, J. INTRODUCTION

The underlying action involves an equal protection challenge to two

Miami Beach ordinances barring short-term rentals in single-family and multi-

family residential districts, respectively. Appellant, Natalie Nichols (an

individual with rentals in a single-family residential district), appeals the trial

court’s order of summary judgment in favor of Appellee, City of Miami Beach,

on Nichols’ equal protection claim denying her motion for continuance of the

summary judgment hearing, and effectively denying her motion to amend the

operative complaint.

For the reasons that follow, we affirm in all respects.

FACTUAL AND PROCEDURAL BACKGROUND

A. The Ordinances

Nichols owns two properties in Miami Beach—a single family home

and a fourplex. Both properties are located within single-family residential

districts. In 2009, the City adopted section 142-905(b)(5) (SF District

Ordinance), prohibiting short term rentals in single-family districts without

exception. The following year, in 2010, the City adopted section 142.1111(a),

a similar ordinance prohibiting short-term rentals in multi-family residential

districts with certain exceptions (MF District Ordinance). Those exceptions

to the MF District Ordinance relate to three areas of Miami Beach: Flamingo

2 Park and Espanola Way Historic Districts; Collins Waterfront Local Historic

District; and the North Beach area. According to the City, the three

exceptions are “limited to specific areas adjacent to commercial or other

more intense use, minimizing the impact of transient rentals on the

surrounding community.” Significant to this appeal, Nichols is affected only

by the SF District Ordinance which provides no exceptions to short-term

rentals.

When passed, the ordinances also included “substantial mandatory

fines” for noncompliance. City of Miami Beach v. Nichols, 314 So. 3d 313,

314 (Fla. 3d DCA 2020).

B. The Lawsuit and the Various Iterations of the Complaint

In June 2018, Nichols filed the underlying lawsuit, asserting three

causes of action seeking declaratory relief, and alleging: (1) both ordinances

violate the equal protection clause of the Florida Constitution; (2) the fines

imposed on homeowners engaged in short-term rentals of their property

constitutes excessive punishment under the Florida Constitution; and (3) the

fines are preempted by state law.

Before the City responded, Nichols amended the complaint, as a

matter of right, to correct a scrivener’s error.

3 On August 27, 2018, the City moved to dismiss the Amended

Complaint on numerous grounds. The trial court held a hearing on the

motion, during which Nichols requested to amend her equal protection and

excessive fine claims; the trial court granted the request as it was “the first

go-round.”

Consistent with its oral pronouncement, the trial court entered an order

dismissing Counts 1 and 2 without prejudice, and granting Nichols leave to

amend. On February 4, 2019, Nichols filed her Second Amended Complaint.

The City again moved to dismiss the equal protection and excessive fines

claims, and answered the preemption claim. Soon after, the parties filed

cross-motions for summary judgment on the preemption claim (Count 3).

The trial court ultimately granted Nichols’ motion for summary judgment on

Count 3 (alleging the fines were preempted by state law), invalidating both

ordinances in their entirety as “illegal and unenforceable.” Upon the City’s

appeal, this Court affirmed in part, and reversed in part, remanding for

severance of the “offending fines to preserve the validity of the Ordinance.”

Nichols, 314 So. 3d at 317.

This Court’s ruling meant that the ordinances’ survived, and Nichols’

challenge to the ordinances continued only under the equal protection claim.

4 On remand in February of 2021, the City set its previously filed motion

to dismiss for a hearing. Nichols responded and, in March of 2021, served

discovery requests on the City, including her first set of interrogatories, first

request for the production of documents, and first request for admissions.

Following a hearing in April of 2021, the trial court granted in part and

denied in part the City’s motion to dismiss, denying the motion on the equal

protection claim to the MF District Ordinance (section 142-1111); granting

the motion on the equal protection challenge to the SF District Ordinance

(section 142-905(b)(5)); dismissing Count 2 (excessive fine) as moot; and

directing the parties to “file a memorandum, or motion supported by a

memorandum of law, addressing whether the remaining claim asserted in

Count One is moot in light of the dismissal of the equal protection challenge

to [the SF District Ordinance].”

In June of 2021, the City moved to dismiss the remaining claim for lack

of standing and/or mootness and, in the alternative, motion for summary

judgment. The City contended that Nichols lacks standing to challenge the

SF District Ordinance because she is not adversely affected by it; her claim

is moot, because even if she were successful, she would still be unable to

rent, on a short-term basis, her properties under the MF District Ordinance;

and the City is entitled to summary judgment on the equal protection claim

5 because it fails on undisputed facts as a matter of law. In support of its

motion, the City filed a declaration from Thomas Mooney, director of the

City’s planning department in which he explained the ordinances and

attached the legislative history for same.

Nichols filed her own memorandum on mootness, maintaining that her

claim challenged the City’s short-term “rental ban and its exceptions as a

whole . . . .” Put differently, her equal protection claim “should either be

allowed to proceed or, if the Court concludes that she has failed to state a

claim, dismissed as a whole.”

The same day, Nichols filed a motion for leave to file a Third Amended

Complaint: “Nichols seeks to plead her equal protection challenge to [the

City’s] scheme that prohibits short-term rentals in some parts of Miami

Beach, while allowing them in others, with greater clarity and specificity to

overcome the defect the Court found in partially dismissing the operative

version of her claim” and to “support her claim with additional facts of which

she became aware after filing her second amended complaint.”

Three months later (August of 2021), Nichols again moved for leave to

amend the Third Amended Complaint, seeking to add Marketwise

6 Investments, LLC as a plaintiff.1 It alleged “one combined cause of action

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