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16 Florida opinions name it 3 courts 1974–2024 3 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.
| Case | Followed | Cited |
|---|---|---|
Zorc v. City of Vero Beachgreen2 sentences2024This is distinguished from “mere ceremonial acceptance or perfunctory ratification of secret actions and decisions.” Id.; see also Zorc v. City of Vero Beach, 722 So. 2d 891, 902 (Fla. 4th DCA 1998) (“[O]nly a full, open hearing will cure a defect arising from a Sunshine Law violation. 2024This is distinguished from “mere ceremonial acceptance or perfunctory ratification of secret actions and decisions.” Id.; see also Zorc v. City of Vero Beach, 722 So. 2d 891, 902 (Fla. 4th DCA 1998) (“[O]nly a full, open hearing will cure a defect arising from a Sunshine Law violation. | 5 | 5 |
Bruckner v. City of Dania Beachgreen2 sentences2019Bd., 995 So. 2d 1068, 1073 (Fla. 5th DCA 2008) (concluding that the Sunshine Law violation “was cured by the subsequent public hearings at which the rezoning plan was adopted,” for “[a] violation may be cured by an independent final action taken in the sunshine that is ‘not merely a ceremonial acceptance of secret actions and not merely a perfunctory ratification of secret decisions at a later meeting open to the public’ [but is, instead,] a full, open and independent public hearing of the disputed issue[, which] can remedy the earlier violation” (quoting Tolar, 398 So. 2d at 429)); Bruckner v 2019Bd., 995 So. 2d 1068, 1073 (Fla. 5th DCA 2008) (concluding that the Sunshine Law violation “was cured by the subsequent public hearings at which the rezoning plan was adopted,” for “[a] violation may be cured by an independent final action taken in the sunshine that is ‘not merely a ceremonial acceptance of secret actions and not merely a perfunctory ratification of secret decisions at a later meeting open to the public’ [but is, instead,] a full, open and independent public hearing of the disputed issue[, which] can remedy the earlier violation” (quoting Tolar, 398 So. 2d at 429)); Bruckner v | 2 | 2 |
Occidental Chemical Company v. Mayogreen2 sentences1985Occidental Chemical Company v. Mayo, 351 So.2d 336, 341-42 (Fla. 1977). 1985Occidental Chemical Company v. Mayo, 351 So.2d 336, 341-42 (Fla. 1977). | 2 | 2 |
Sarasota Citizens for Responsible Government v. City of Sarasotagreen2 sentences2021"Sunshine Law violations can be cured by 'independent, final action in the sunshine,' " as "distinguished from mere ceremonial acceptance or perfunctory ratification of secret actions and decisions." Sarasota Citizens, 48 So. 3d at 765 (quoting Tolar v. School Bd. of Liberty Cnty., 398 So. 2d 427, 429 (Fla. 1981)). "[O]nly a full, open hearing will cure a defect arising from a Sunshine Law violation." Id. (alteration in original) (quoting Zorc v. City of Vero Beach, 722 So. 2d 891, 903 (Fla. 4th DCA 1998)). 2021"Sunshine Law violations can be cured by 'independent, final action in the sunshine,' " as "distinguished from mere ceremonial acceptance or perfunctory ratification of secret actions and decisions." Sarasota Citizens, 48 So. 3d at 765 (quoting Tolar v. School Bd. of Liberty Cnty., 398 So. 2d 427, 429 (Fla. 1981)). "[O]nly a full, open hearing will cure a defect arising from a Sunshine Law violation." Id. (alteration in original) (quoting Zorc v. City of Vero Beach, 722 So. 2d 891, 903 (Fla. 4th DCA 1998)). | 1 | 2 |
Town of Palm Beach v. Gradisongreen2 sentences2014The fact that the MSA was tentative and conditioned upon further approval does not cure any prior Sunshine Law violation as the purpose of the Sunshine Law is to “prevent at nonpublic meetings the crystallization of secret decisions to a point just short of ceremonial acceptance.” Zorc v. City of Vero Beach, 722 So.2d 891, 896 (Fla. 4th DCA 1998) (citing Town of Palm Beach v. Gradison, 296 So.2d 473, 477 (Fla.1974)). 1995Id. | 1 | 2 |
Tolar v. School Bd. of Liberty Countygreen2 sentences2021"Sunshine Law violations can be cured by 'independent, final action in the sunshine,' " as "distinguished from mere ceremonial acceptance or perfunctory ratification of secret actions and decisions." Sarasota Citizens, 48 So. 3d at 765 (quoting Tolar v. School Bd. of Liberty Cnty., 398 So. 2d 427, 429 (Fla. 1981)). "[O]nly a full, open hearing will cure a defect arising from a Sunshine Law violation." Id. (alteration in original) (quoting Zorc v. City of Vero Beach, 722 So. 2d 891, 903 (Fla. 4th DCA 1998)). 2021"Sunshine Law violations can be cured by 'independent, final action in the sunshine,' " as "distinguished from mere ceremonial acceptance or perfunctory ratification of secret actions and decisions." Sarasota Citizens, 48 So. 3d at 765 (quoting Tolar v. School Bd. of Liberty Cnty., 398 So. 2d 427, 429 (Fla. 1981)). "[O]nly a full, open hearing will cure a defect arising from a Sunshine Law violation." Id. (alteration in original) (quoting Zorc v. City of Vero Beach, 722 So. 2d 891, 903 (Fla. 4th DCA 1998)). | 1 | 1 |
Smith v. City of Fort Myersgreen2 sentences2021The Sunshine Law "on its face[] gives the appellant standing without regard to whether he suffered a special injury." Godheim v. City of Tampa, 426 So. 2d 1084, 1088 (Fla. 2d DCA 1983); see also Smith v. City of Fort Myers, 944 So. 2d 1092, 1095 (Fla. 2d DCA 2006) (citing Godheim and recognizing that the Sunshine Law expressly confers standing). 4 A "district school board has the constitutional duty and responsibility to select and provide adequate instructional materials for all students." § 1006.28(1), Fla. Stat. (2016);4 see also art. 2021The Sunshine Law "on its face[] gives the appellant standing without regard to whether he suffered a special injury." Godheim v. City of Tampa, 426 So. 2d 1084, 1088 (Fla. 2d DCA 1983); see also Smith v. City of Fort Myers, 944 So. 2d 1092, 1095 (Fla. 2d DCA 2006) (citing Godheim and recognizing that the Sunshine Law expressly confers standing). 4 A "district school board has the constitutional duty and responsibility to select and provide adequate instructional materials for all students." § 1006.28(1), Fla. Stat. (2016);4 see also art. | 1 | 1 |
Godheim v. City of Tampagreen2 sentences2021The Sunshine Law "on its face[] gives the appellant standing without regard to whether he suffered a special injury." Godheim v. City of Tampa, 426 So. 2d 1084, 1088 (Fla. 2d DCA 1983); see also Smith v. City of Fort Myers, 944 So. 2d 1092, 1095 (Fla. 2d DCA 2006) (citing Godheim and recognizing that the Sunshine Law expressly confers standing). 4 A "district school board has the constitutional duty and responsibility to select and provide adequate instructional materials for all students." § 1006.28(1), Fla. Stat. (2016);4 see also art. 2021The Sunshine Law "on its face[] gives the appellant standing without regard to whether he suffered a special injury." Godheim v. City of Tampa, 426 So. 2d 1084, 1088 (Fla. 2d DCA 1983); see also Smith v. City of Fort Myers, 944 So. 2d 1092, 1095 (Fla. 2d DCA 2006) (citing Godheim and recognizing that the Sunshine Law expressly confers standing). 4 A "district school board has the constitutional duty and responsibility to select and provide adequate instructional materials for all students." § 1006.28(1), Fla. Stat. (2016);4 see also art. | 1 | 1 |
Jackson-Shaw Co. v. Jacksonville Aviation Authoritygreen2 sentences2019Bd., 995 So. 2d 1068, 1073 (Fla. 5th DCA 2008) (concluding that the Sunshine Law violation “was cured by the subsequent public hearings at which the rezoning plan was adopted,” for “[a] violation may be cured by an independent final action taken in the sunshine that is ‘not merely a ceremonial acceptance of secret actions and not merely a perfunctory ratification of secret decisions at a later meeting open to the public’ [but is, instead,] a full, open and independent public hearing of the disputed issue[, which] can remedy the earlier violation” (quoting Tolar, 398 So. 2d at 429)); Bruckner v 2019Bd., 995 So. 2d 1068, 1073 (Fla. 5th DCA 2008) (concluding that the Sunshine Law violation “was cured by the subsequent public hearings at which the rezoning plan was adopted,” for “[a] violation may be cured by an independent final action taken in the sunshine that is ‘not merely a ceremonial acceptance of secret actions and not merely a perfunctory ratification of secret decisions at a later meeting open to the public’ [but is, instead,] a full, open and independent public hearing of the disputed issue[, which] can remedy the earlier violation” (quoting Tolar, 398 So. 2d at 429)); Bruckner v | 1 | 1 |
Finch v. Seminole County School Bd.green2 sentences2019Bd., 995 So. 2d 1068, 1073 (Fla. 5th DCA 2008) (concluding that the Sunshine Law violation “was cured by the subsequent public hearings at which the rezoning plan was adopted,” for “[a] violation may be cured by an independent final action taken in the sunshine that is ‘not merely a ceremonial acceptance of secret actions and not merely a perfunctory ratification of secret decisions at a later meeting open to the public’ [but is, instead,] a full, open and independent public hearing of the disputed issue[, which] can remedy the earlier violation” (quoting Tolar, 398 So. 2d at 429)); Bruckner v 2019Bd., 995 So. 2d 1068, 1073 (Fla. 5th DCA 2008) (concluding that the Sunshine Law violation “was cured by the subsequent public hearings at which the rezoning plan was adopted,” for “[a] violation may be cured by an independent final action taken in the sunshine that is ‘not merely a ceremonial acceptance of secret actions and not merely a perfunctory ratification of secret decisions at a later meeting open to the public’ [but is, instead,] a full, open and independent public hearing of the disputed issue[, which] can remedy the earlier violation” (quoting Tolar, 398 So. 2d at 429)); Bruckner v | 1 | 1 |
Hough v. Stembridgegreen2 sentences2018Sunshine Law.” Hough v. Stembridge, 278 So. 2d 288, 289 (Fla. 3d DCA 1973). 2018Sunshine Law.” Hough v. Stembridge, 278 So. 2d 288, 289 (Fla. 3d DCA 1973). | 1 | 1 |
Bassett v. Braddockgreen2 sentences2010See Bassett v. Braddock, 262 So.2d 425, 428-29 (Fla.1972) (concluding that a subsequent open, public vote cured, corrected, and rendered “sunshine bright” an initial violation of section 286.011 relating to the election of school board officers by secret written ballot); Bruckner v. City of Dania Beach, 823 So.2d 167, 171 (Fla. 4th DCA 2002) (stating that a Sunshine Law violation “can be cured by independent final action completely in the Sunshine”). 2010See Bassett v. Braddock, 262 So.2d 425, 428-29 (Fla.1972) (concluding that a subsequent open, public vote cured, corrected, and rendered “sunshine bright” an initial violation of section 286.011 relating to the election of school board officers by secret written ballot); Bruckner v. City of Dania Beach, 823 So.2d 167, 171 (Fla. 4th DCA 2002) (stating that a Sunshine Law violation “can be cured by independent final action completely in the Sunshine”). | 1 | 1 |
Monroe Cty. v. Pigeon Key Hist. Parkgreen2 sentences2010Such violation will not be cured by a perfunctory ratification of the action taken outside of the sunshine.”); Monroe County v. Pigeon Key Historical Park, Inc., 647 So.2d 857, 861 (Fla. 3d DCA 1994) (“Governmental actions will not be voided whenever governmental bodies have met in secret where sufficiently corrective final action has been taken.”). 2010Such violation will not be cured by a perfunctory ratification of the action taken outside of the sunshine.”); Monroe County v. Pigeon Key Historical Park, Inc., 647 So.2d 857, 861 (Fla. 3d DCA 1994) (“Governmental actions will not be voided whenever governmental bodies have met in secret where sufficiently corrective final action has been taken.”). | 1 | 1 |
McGurn v. Scottgreen2 sentences1995Warehouse Co. v. Webb, 304 So.2d 97, 99 (Fla. 1972); see generally McGurn v. Scott, 596 So.2d 1042 (Fla. 1992). 1995Warehouse Co. v. Webb, 304 So.2d 97, 99 (Fla. 1972); see generally McGurn v. Scott, 596 So.2d 1042 (Fla. 1992). | 1 | 1 |
SLT Warehouse Company v. Webbgreen2 sentences1995Warehouse Co. v. Webb, 304 So.2d 97, 99 (Fla. 1972); see generally McGurn v. Scott, 596 So.2d 1042 (Fla. 1992). 1995Warehouse Co. v. Webb, 304 So.2d 97, 99 (Fla. 1972); see generally McGurn v. Scott, 596 So.2d 1042 (Fla. 1992). | 1 | 1 |
| Case | Negative | Cited |
|---|---|---|
| No negative-treatment citations attached to this issue in Florida. Read the followed side critically anyway. | ||
| Case | Cited | Years |
|---|---|---|
National Council on Compensation Insurance, Florida Office of Insurance Regulation, and David Altmaier, in his official capacity as Commissioner of the Florida Office of Insurance Regulation v. James F. Fee Jr., Individually
green
2 sentences2023Fee, 219 So. 3d at 177 ; see also Sarasota Citizens for Responsible Gov’t, 48 So. 3d at 761 . 2023Fee, 219 So. 3d at 177 ; see also Sarasota Citizens for Responsible Gov’t, 48 So. 3d at 761 . | 1 | 2023–2023 |
Leach-Wells v. City of Bradenton
green
2 sentences2017It went on to conclude that “if a meeting was required and none was held, a Sunshine Law violation occurred.” Id. 2017It went on to conclude that “if a meeting was required and none was held, a Sunshine Law violation occurred.” Id. | 1 | 2017–2017 |
Preston Carroll Company, Inc. v. Florida Keys Aqueduct Authority
green
2 sentences1997The Sunshine Law violation was the sine qua non of the instant bid protest, given the fact that the committee had ranked Silver Express third, and as such, the company lacked the standing to succeed on its other claims of error in the committee’s decision. 3 See Preston Carroll Co., Inc. v. Florida Keys Aqueduct, 400 So.2d 524 (Fla. 3d DCA 1981). 1997The Sunshine Law violation was the sine qua non of the instant bid protest, given the fact that the committee had ranked Silver Express third, and as such, the company lacked the standing to succeed on its other claims of error in the committee’s decision. 3 See Preston Carroll Co., Inc. v. Florida Keys Aqueduct, 400 So.2d 524 (Fla. 3d DCA 1981). | 1 | 1997–1997 |
Bigelow v. Howze
green
2 sentences1995Id. at 647-48 . 1995Id. at 647-48 . | 1 | 1995–1995 |
Bennett v. Warden
green
2 sentences1983I fully agree with the majority's approval of Bennett v. Warden, 333 So.2d 97 (Fla. 2d DCA 1976), and that decision's premise that a Sunshine Law violation does not occur when a government executive uses his staff for fact-finding and assistance in fulfilling his duties. 1983I fully agree with the majority's approval of Bennett v. Warden, 333 So.2d 97 (Fla. 2d DCA 1976), and that decision's premise that a Sunshine Law violation does not occur when a government executive uses his staff for fact-finding and assistance in fulfilling his duties. | 1 | 1983–1983 |
BMZ CORP. v. City of Oakland Park
green
1 sentence1982The trial court reviewed the present motion and properly found it warranted neither a hearing nor relief, apparently concluding as we did in BMZ Corp. v. City of Oakland Park, 415 So.2d 735 (Fla. 4th DCA 1982), that the inadequate, sketchy dialogue in the mayor’s deposition did not show a sunshine law .violation. 1 Accordingly, the order is affirmed. | 1 | 1982–1982 |
City of Miami Beach v. Berns
green
2 sentences1974The Supreme Court, in discussing a Sunshine Law violation involving a city council, Berns v. City of Miami Beach, supra, mentions this requirement of recording minutes. 1974The Supreme Court, in discussing a Sunshine Law violation involving a city council, Berns v. City of Miami Beach, supra, mentions this requirement of recording minutes. | 1 | 1974–1974 |
Counted by distinct opinions that both name this issue and are annotated to the section; sections every opinion cites regardless of issue are not filtered here, so read the counts against the total above.
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.