facial constitutional challenge (Florida) · Go Syfert
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facial constitutional challenge in Florida

21 Florida opinions name it 2 courts 2003–2026 4 in the last five years

The cases below were cited by Florida courts in a sentence that names this issue. Sides come from how each citing opinion treated the case (Syfertize flag on that citation), so a case can appear on both: that is where the law is contested. A red or yellow chip is the case's own overall treatment.

Followed or applied (16)

CaseFollowedCited
Cashatt v. Stategreen
fladistctapp · 2004 · cited in 3 Florida opinions naming this issue, 2012–2026
2 sentences

2026See Cashatt v. State, 873 So. 2d 430, 434 (Fla. 1st DCCA 2004) (explaining that a facial constitutional challenge “must fail unless no set of circumstances exists in which the statute can be constitutionally applied”); see also Crist v. Ervin, 56 So. 3d 745, 747 (Fla. 2010) (“If any state of facts, known or to be assumed, justify the law, the court’s power of inquiry ends.” (citation omitted)); Smalley v. Duke Energy Fla., Inc., 154 So. 3d 439, 441 (Fla. 2d DCA 2014) (“A facial challenge fails when a statute has a ‘plainly legitimate sweep.’” (quoting Wash. State Grange, 552 U.S. at 449 )).

2017Delaney v. Tucker, 88 So.3d 1036, 1037 (Fla. 1st DCA2012) (stating that a “direct appeal is the proper avenue for a facial constitutional, challenge to a criminal statute”). 4 A “facial challenge to a statute is more difficult than an ‘as applied’ challenge, because the challenger must establish that no set of circumstances exists under which the statute would be valid. ... such a challenge must fail unless no set of circumstances exists in which the statute can be constitutionally applied.” Cashatt v. State,, 873 So.2d 430, 434 (Fla. 1st DCA 2004).

33
Fla. Dept. of Rev. v. City of Gainesvillegreen
fla · 2005 · cited in 2 Florida opinions naming this issue, 2007–2016
2 sentences

2016See Fla. Dep’t of Revenue v. City of Gainesville, 918 So.2d 250, 265 (Fla.2005).(“[I]n a facial constitutional challenge, we determine only whether there is any set of circumstances under which the challenged enactment might be upheld.”).

2016See Fla. Dep’t of Revenue v. City of - 51 - Gainesville, 918 So. 2d 250, 265 (Fla. 2005) (“[I]n a facial constitutional challenge, we determine only whether there is any set of circumstances under which the challenged enactment might be upheld.”).

22
Henley v. City of Cape Coralgreen
fladistctapp · 1974 · cited in 2 Florida opinions naming this issue, 2010–2010
2 sentences

2010See Henley v. City of Cape Coral, 292 So.2d 410, 411 (Fla. 2d DCA 1974).

2010See Henley v. City of Cape Coral, 292 So.2d 410, 411 (Fla. 2d DCA 1974).

22
State v. Balesgreen
fla · 1977 · cited in 2 Florida opinions naming this issue, 2005–2010
2 sentences

2010“If any state of facts, known or to be assumed, justify the law, the court’s power of inquiry ends.” State v. Bales, 343 So.2d 9, 11 (Fla.1977).

2005See Bales, 343 So.2d at 11 ("[A]ny legislative enactment ;carries a strong presumption of constitutionality, including a rebuttable presumption of the existence of necessary factual support in its provisions.

22
Crist v. Ervingreen
fla · 2010 · cited in 1 Florida opinions naming this issue, 2026–2026
1 sentence

2026See Cashatt v. State, 873 So. 2d 430, 434 (Fla. 1st DCCA 2004) (explaining that a facial constitutional challenge “must fail unless no set of circumstances exists in which the statute can be constitutionally applied”); see also Crist v. Ervin, 56 So. 3d 745, 747 (Fla. 2010) (“If any state of facts, known or to be assumed, justify the law, the court’s power of inquiry ends.” (citation omitted)); Smalley v. Duke Energy Fla., Inc., 154 So. 3d 439, 441 (Fla. 2d DCA 2014) (“A facial challenge fails when a statute has a ‘plainly legitimate sweep.’” (quoting Wash. State Grange, 552 U.S. at 449 )).

11
Smalley v. Duke Energy Florida, Inc.green
fladistctapp · 2014 · cited in 1 Florida opinions naming this issue, 2026–2026
1 sentence

2026See Cashatt v. State, 873 So. 2d 430, 434 (Fla. 1st DCCA 2004) (explaining that a facial constitutional challenge “must fail unless no set of circumstances exists in which the statute can be constitutionally applied”); see also Crist v. Ervin, 56 So. 3d 745, 747 (Fla. 2010) (“If any state of facts, known or to be assumed, justify the law, the court’s power of inquiry ends.” (citation omitted)); Smalley v. Duke Energy Fla., Inc., 154 So. 3d 439, 441 (Fla. 2d DCA 2014) (“A facial challenge fails when a statute has a ‘plainly legitimate sweep.’” (quoting Wash. State Grange, 552 U.S. at 449 )).

11
Palko v. Connecticutred
scotus · 1937 · cited in 1 Florida opinions naming this issue, 2025–2025
1 sentence

2025"Substantive due process protects fundamental rights that are so 'implicit in the concept of ordered liberty [that] neither liberty nor justice would exist if they were sacrificed.' " Jackson v. State, 191 So. 3d 423, 428 (Fla. 2016) (quoting Palko v. Connecticut, 302 U.S. 319, 325-26 (1937), overruled on other grounds by Benton v. Maryland, 395 U.S. 784 (1969)).

11
Jermaine C. Jackson v. State of Floridagreen
fla · 2016 · cited in 1 Florida opinions naming this issue, 2025–2025
1 sentence

2025"Substantive due process protects fundamental rights that are so 'implicit in the concept of ordered liberty [that] neither liberty nor justice would exist if they were sacrificed.' " Jackson v. State, 191 So. 3d 423, 428 (Fla. 2016) (quoting Palko v. Connecticut, 302 U.S. 319, 325-26 (1937), overruled on other grounds by Benton v. Maryland, 395 U.S. 784 (1969)).

11
Fraternal Order of Police, Miami Lodge 20 v. City of Miamigreen
fla · 2018 · cited in 1 Florida opinions naming this issue, 2020–2020
1 sentence

2020Fraternal Order of Police, Miami Lodge 20 v. City of Miami, 243 So. 3d 894, 897 (Fla. 2018).

11
Mobley v. Stategreen
fladistctapp · 2012 · cited in 1 Florida opinions naming this issue, 2017–2017
1 sentence

2017Delaney v. Tucker, 88 So.3d 1036, 1037 (Fla. 1st DCA2012) (stating that a “direct appeal is the proper avenue for a facial constitutional, challenge to a criminal statute”). 4 A “facial challenge to a statute is more difficult than an ‘as applied’ challenge, because the challenger must establish that no set of circumstances exists under which the statute would be valid. ... such a challenge must fail unless no set of circumstances exists in which the statute can be constitutionally applied.” Cashatt v. State,, 873 So.2d 430, 434 (Fla. 1st DCA 2004).

11
Seminole County v. Coral Gables Federal Savings & Loan Ass'ngreen
fladistctapp · 1997 · cited in 1 Florida opinions naming this issue, 2015–2015
1 sentence

2015In Seminole County v. Coral Gables Federal Savings & Loan Ass’n, 691 So.2d 614, 614 (Fla. 5th DCA 1997), the Fifth District rejected an assertion that section 73.092 is unconstitutional because it divests the judiciary of the ability to determine reasonable attorney’s fees for a private property owner.

11
Dane P. Abdool v. Pam Bondi, etc.green
fla · 2014 · cited in 1 Florida opinions naming this issue, 2014–2014
1 sentence

2014Abdool v. Bondi, 141 So.3d 529, 538 (Fla. 2014).

11
Carreras v. Stategreen
fladistctapp · 2012 · cited in 1 Florida opinions naming this issue, 2012–2012
1 sentence

2012See, e.g., Carreras v. State, 81 So.3d 590 (Fla. 5th DCA 2012) (affirming judgment and sentence in direct appeal challenging facial constitutionality of drug possession statute based on Shelton ); Cashatt v. State, 873 So.2d 430, 434 (Fla. 1st DCA 2004).

11
Miami-Dade County v. Omnipoint Holdings, Inc.green
fla · 2003 · cited in 1 Florida opinions naming this issue, 2007–2007
1 sentence

2007We agree with the developer that a petition for writ of certiorari cannot be used for this purpose. "[A] petition seeking certiorari review is not the proper procedural vehicle to challenge the constitutionality of a statute or ordinance." Miami-Dade County v. Omnipoint Holdings, Inc., 863 So.2d 195, 199 (Fla.2003) (citation omitted).

11
Rahmani v. Stategreen
texapp · 1988 · cited in 1 Florida opinions naming this issue, 2005–2005
1 sentence

2005See Rahmani v. State, 748 S.W.2d 618, 626 (Tex.App.Ct.1988).

11
Reno v. Floresgreen
scotus · 1993 · cited in 1 Florida opinions naming this issue, 2004–2004
2 sentences

2004A facial constitutional challenge under the Establishment Clause typically occurs without "a record as to how the statute had actually been applied." Bowen v. Kendrick, 487 U.S. 589, 600-01 , 108 S.Ct. 2562, 2569-70 , 101 L.Ed.2d 520 (1988); see also Reno v. Flores, 507 U.S. 292, 300-01 , 113 S.Ct. 1439, 1446 , 123 L.Ed.2d 1 (1993)(explaining that a facial challenge is assessed without reference to factual findings or evidence of particular applications).

2004A facial constitutional challenge under the Establishment Clause typically occurs without "a record as to how the statute had actually been applied." Bowen v. Kendrick, 487 U.S. 589, 600-01 , 108 S.Ct. 2562, 2569-70 , 101 L.Ed.2d 520 (1988); see also Reno v. Flores, 507 U.S. 292, 300-01 , 113 S.Ct. 1439, 1446 , 123 L.Ed.2d 1 (1993)(explaining that a facial challenge is assessed without reference to factual findings or evidence of particular applications).

11

Distinguished, questioned or overruled (0)

CaseNegativeCited
No negative-treatment citations attached to this issue in Florida. Read the followed side critically anyway.

Also cited on this issue (10)

CaseCitedYears
Washington State Grange v. Washington State Republican Party green
scotus · 2008
1 sentence

2026See Cashatt v. State, 873 So. 2d 430, 434 (Fla. 1st DCCA 2004) (explaining that a facial constitutional challenge “must fail unless no set of circumstances exists in which the statute can be constitutionally applied”); see also Crist v. Ervin, 56 So. 3d 745, 747 (Fla. 2010) (“If any state of facts, known or to be assumed, justify the law, the court’s power of inquiry ends.” (citation omitted)); Smalley v. Duke Energy Fla., Inc., 154 So. 3d 439, 441 (Fla. 2d DCA 2014) (“A facial challenge fails when a statute has a ‘plainly legitimate sweep.’” (quoting Wash. State Grange, 552 U.S. at 449 )).

12026–2026
Benton v. Maryland green
scotus · 1969
1 sentence

2025"Substantive due process protects fundamental rights that are so 'implicit in the concept of ordered liberty [that] neither liberty nor justice would exist if they were sacrificed.' " Jackson v. State, 191 So. 3d 423, 428 (Fla. 2016) (quoting Palko v. Connecticut, 302 U.S. 319, 325-26 (1937), overruled on other grounds by Benton v. Maryland, 395 U.S. 784 (1969)).

12025–2025
Key Haven Associated Enterprises, Inc. v. Bd. of Trustees of Internal Imp. Trust Fund green
fla · 1982
1 sentence

2024Id. at 157 .

12024–2024
Watts v. United States green
scotus · 1969
2 sentences

2021We conclude the statute is amenable to a construction under which it does not reach a 3 substantial amount of constitutionally protected speech in furthering the State’s valid, even “overwhelming, interest in protecting the safety of its” officers and “in allowing [them] to perform [their] duties without interference from threats of physical violence.” 1 Watts v. United States, 394 U.S. 705, 707 , 89 S. Ct. 1399, 1401 , 22 L.

2021We conclude the statute is amenable to a construction under which it does not reach a 3 substantial amount of constitutionally protected speech in furthering the State’s valid, even “overwhelming, interest in protecting the safety of its” officers and “in allowing [them] to perform [their] duties without interference from threats of physical violence.” 1 Watts v. United States, 394 U.S. 705, 707 , 89 S. Ct. 1399, 1401 , 22 L.

12021–2021
State v. Gainesville Woman Care LLC green
fladistctapp · 2016
2 sentences

2017Finally, the First District held that the trial court’s order was also deficient for “failing to address the legal requirements for a facial constitutional challenge to a statute.” Id.

2017Finally, the First District held that the trial court’s order was also deficient for “failing to address the legal requirements for a facial constitutional challenge to a statute.” Id.

12017–2017
Goin v. Commission on Ethics green
fladistctapp · 1995
1 sentence

2016Cf. Goin v. Comm’n on Ethics, 658 So.2d 1131 (Fla. 1st DCA 1995) (considering but rejecting public employee’s challenge to the facial constitutionality of the ethics statute he was found to have violated in the final order and public report); Barker v. Comm’n on Ethics, 654 So.2d 646 (Fla. 3d DCA 1995) (reversing Commission’s final order and public report because the statute that the report found the public official to have violated was facially unconstitutional), remanded, 677 So.2d 254 (Fla. 1996).

12016–2016
Barker v. State, Commission on Ethics neutral
fladistctapp · 1995
1 sentence

2016Cf. Goin v. Comm’n on Ethics, 658 So.2d 1131 (Fla. 1st DCA 1995) (considering but rejecting public employee’s challenge to the facial constitutionality of the ethics statute he was found to have violated in the final order and public report); Barker v. Comm’n on Ethics, 654 So.2d 646 (Fla. 3d DCA 1995) (reversing Commission’s final order and public report because the statute that the report found the public official to have violated was facially unconstitutional), remanded, 677 So.2d 254 (Fla. 1996).

12016–2016
Commission on Ethics v. Barker green
fla · 1996
1 sentence

2016Cf. Goin v. Comm’n on Ethics, 658 So.2d 1131 (Fla. 1st DCA 1995) (considering but rejecting public employee’s challenge to the facial constitutionality of the ethics statute he was found to have violated in the final order and public report); Barker v. Comm’n on Ethics, 654 So.2d 646 (Fla. 3d DCA 1995) (reversing Commission’s final order and public report because the statute that the report found the public official to have violated was facially unconstitutional), remanded, 677 So.2d 254 (Fla. 1996).

12016–2016
Bowen v. Kendrick green
scotus · 1988
2 sentences

2004A facial constitutional challenge under the Establishment Clause typically occurs without "a record as to how the statute had actually been applied." Bowen v. Kendrick, 487 U.S. 589, 600-01 , 108 S.Ct. 2562, 2569-70 , 101 L.Ed.2d 520 (1988); see also Reno v. Flores, 507 U.S. 292, 300-01 , 113 S.Ct. 1439, 1446 , 123 L.Ed.2d 1 (1993)(explaining that a facial challenge is assessed without reference to factual findings or evidence of particular applications).

2004A facial constitutional challenge under the Establishment Clause typically occurs without "a record as to how the statute had actually been applied." Bowen v. Kendrick, 487 U.S. 589, 600-01 , 108 S.Ct. 2562, 2569-70 , 101 L.Ed.2d 520 (1988); see also Reno v. Flores, 507 U.S. 292, 300-01 , 113 S.Ct. 1439, 1446 , 123 L.Ed.2d 1 (1993)(explaining that a facial challenge is assessed without reference to factual findings or evidence of particular applications).

12004–2004
Harvey v. State green
fla · 2003
2 sentences

2003Id., 848 So.2d at 1063 .

2003Id., 848 So.2d at 1063 .

12003–2003

Where else courts name it

CA 98 (1990–2026) IL 76 (2014–2026) TX 66 (1995–2026) NY 31 (1991–2026) OH 29 (1997–2026) FL 21 (2003–2026) PA 18 (1992–2026) WI 18 (2002–2025) NC 14 (1998–2023) IN 12 (1997–2024) WA 12 (1997–2026) CO 11 (1983–2026) MD 11 (1998–2025) TN 9 (2009–2026) VA 8 (2002–2025) AL 6 (2003–2018) NJ 6 (2001–2021) IA 5 (1979–2025) AZ 5 (2007–2025) UT 5 (1995–2019) MN 5 (1993–2026) NE 4 (2019–2024) MT 4 (2018–2025) MA 4 (1996–2006) LA 4 (2015–2020) MI 3 (2012–2025) KY 3 (2022–2025) ID 3 (1985–2009) AK 3 (2019–2024) KS 2 (2020–2026) DC 2 (1997–2021) HI 2 (2015–2023) ME 2 (2015–2021) NM 2 (1994–1994)

Opinions by the citing court's state. A doctrine retained in one state and abandoned in another shows up here as a year span that stalls.

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