HomeMy WebLinkAboutSubmittal-District 2-Memorandum of Law Ultra permit for alcoholic beveragesMEMORANDUM OF LAW
Submitted into the public
record in connection with
item 'T 3 on (-f I2LI I IL.1
City Clerk
1. Lack of Prior Enforcement Does Not Estop the City From Enforcing Sec.
38-115(b) or Sec. 38-70(c)
Sec. 38-115(b) provides that there shall be no permits for alcoholic beverages
issued in connection with a musical event of the type which requires extraordinary
security measures. Specifically, Section 38-115(b) provides, "There shall be no such
permits [permit for the sale or dispensing of alcoholic beverages, including beer and
wine] issued in connection with a hard rock, rap, heavy metal, or other musical event of
the type which requires extraordinary security measures."
Section 38-70 governs the sale or dispensing of beer and/or wine for special
events or programs in city parks (including Bayfront Park). Section 38-70(c) provides,
"Unless approved by the city commission, there shall be no permits issued in
connection with any musical event or program of the type which historically requires
extraordinary security measures, based upon prudent police protection (commonly
referred to as "rock concerts")."
The City's apparent lack of prior enforcement of Sections 38-115(b) and 38-70(c)
in connection with the Ultra festival does not render those Sections any less enforceable
now. The City is not estopped from enforcing Sections 38-115(b) and 38-70(c).
Generally, the failure of a city to enforce a zoning regulation in one or many
cases, does not affect the city's power to enforce the law at issue in others. Stocks v.
Lee, 198 So. 211, 212 (Fla. 1940) ("It is also recognized as a generally established
principle of law that the acquiescence of the municipal authorities in the violation of an
ordinance or regulation is no defense. In other words, that the failure of the authorities
to enforce the ordinance against others constitutes no defense in favor of one who is
prosecuted under such ordinance."); City of Miami Beach v. Lincoln Investments, Inc.,
214 So.2d 496 (Fla. 3d DCA 1968) ("Appellee argues that the finding of the trial court
that the city has allowed 'special liquor service bar licenses, as exceptions to the
population limitations' and has previously granted special liquor service bar licenses in
the area where the relator has sought such a license amounts to a finding that the
ordinance itself is arbitrary and unreasonable and a denial of equal protection of the
law. We think this does not follow. The failure of a governing authority to enforce the law
properly is not a ground for the courts to disregard that law."); Ross v. City of Miami,
205 So. 2d 545, 547 (Fla. 3d DCA 1968) ("The trial court accepted as fact the plaintiffs
assertion that the city, in other instances, had granted variances for use of property for
gasoline service stations notwithstanding the 750-foot distance restriction, but held that
was 'no criterion to a determination of this case,' citing as authority the case of City of
Miami Beach v. State ex rel. Patrician Hotel, 145 Fla. 716, 200 So. 213, in which it was
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held that the failure of a city in one case, or in many cases, to enforce regulations of an
ordinance enacted under the police power, does not preclude the enforcement thereof
in other cases."); City of Miami v. Walker, 169 So.2d 842 (Fla. 3d DCA 1964), cert.
denied, 176 So.2d 511 (FIa.1965) ("We observe that the chancellor placed considerable
weight, as do the appellees, upon the fact that the City of Miami has permitted several
hundred filling stations within the distance prohibitions of the ordinance and has granted
some 75 variances from this requirement. Although great weight has been placed on
this fact by the chancellor and the appellees, nevertheless it is without a conclusion that
the city has waived or is otherwise equitably estopped from enforcing the terms of the
ordinance. Whether the city has permitted several hundred or only a few filling stations
to be within the prohibited distance requirement of the ordinance is conclusive of
nothing insofar as appellees are concerned.").
Note that City of Miami v. Walker, Ross v. City of Miami and City of Miami Beach
v. Lincoln all rely upon City of Miami Beach v. State ex rel. Patrician Hotel Co., 200 So.
213 (Fla. 1941), in which the Florida Supreme Court held, "[t]he ordinance is a police
regulation and it is elementary that the failure to enforce a valid police regulation in one
case, or in many cases, does not affect the power to enforce it in other cases."'
Equitable estoppel against the City. In Monroe County v. Hemisphere Equity
Realty, Inc., 634 So. 2d 745 (Fla. 3d DCA 1994), the Third District held that lax
enforcement against third parties did not estop the government from enforcement under
the facts of that case. The Court stated:
The trial court erred in ruling that Monroe County was
equitably estopped from enforcing its regulations that
established a completion period for major development. The
evidence, viewed in a light most favorable to the developer,
does not support a finding of estoppel.
Equitable estoppel is to be applied against the state
only in rare instances and under exceptional
circumstances. To sustain a claim of estoppel against
the state or one of its subdivisions, there must be (1)
1 Note that City of Miami Beach v. State ex rel. Patrician Hotel Co., 200 So. 213 (Fla. 1941), was
overruled in part on other grounds by City of Miami v. Kichinko, 22 So. 2d 627 (Fla. 1945). The Patrician
case continues to be cited and the Kichinko case overruled the Patrician case on other grounds. See, 2A
Fla. Jur 2d Alcoholic Beverages § 62 ("Failure of the municipality in one instance, or even in several
instances, to enforce an ordinance restricting the location of a retail liquor businesses in a given area
does not affect its power to enforce the ordinance in other cases.") (citing City of Miami Beach v. State ex
rel. Patrician Hotel Co., 145 Fla. 716, 200 So. 213 (1941) (overruled in part on other grounds by, City of
Miami v. Kichinko, 156 Fla. 128, 22 So. 2d 627 (1945)).). The Kichinko case affirmed a trial court's
decision that a City of Miami liquor ordinance was invalid. The basis of the Kichinko decision was that
municipalities possess only such power as is conferred by express or implied provisions of law and that
the Legislature, in enacting the State Beverage Law, intended to inhibit all powers of a municipality over
the subject of intoxicating liquors, except those powers specifically enumerated therein.
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Submitted into the public
record in connection with
item DI.3 on 04/24/14
City Clerk
a representation as to some material fact by the party
estopped to the party claiming estoppel; (2) reliance
upon the representation by the party claiming
estoppel; and (3) a change in such party's position
caused by his reliance on the representation to his
detriment. Furthermore, the act on which the
aggrieved party relied must be one on which he had a
right to rely.
Calusa Golf, Inc. v. Dade County, 426 So.2d 1165, 1167
(Fla. 3d DCA 1983) (citations omitted). No such rare
instance or unusual circumstance exists in this case. Even if
the County had been lax in its enforcement of its regulation
as against other developers, Texas Largo was not entitled to
rely on the County's failure to enforce its regulations against
third parties. See Calusa Golf, 426 So.2d at 1167 (stranger
to transaction on which alleged estoppel arises cannot rely
on representations made to third parties). Furthermore, the
act giving rise to the alleged estoppel "must include some
positive act on the part of some officer of the state upon
which the aggrieved party had a right to rely and did rely to
its detriment." Ogden v. State Dept. of Transportation, 601
So.2d 1300, 1302 (Fla. 3d DCA 1992) (emphasis added)
(quoting Greenhut Constr. Co. v. Henry A. Knott, Inc., 247
So.2d 517, 524 (Fla. 1st DCA 1971)). Here, the trial court
misconstrued the legal doctrine of equitable estoppel when it
ruled that Texas Largo was entitled to proceed with its
development based upon the County's failure to act against
third parties.
Estoppel not applicable to transactions which are forbidden by ordinance. The
estoppel principal may not apply here because the Third District has recognized that
estoppel generally has no application to transactions that are forbidden by municipal
ordinance. In Brickell Bay Club Condominium Ass'n v. Hemstatdt, 512 So. 2d 994, 996
(Fla. 3d DCA 1987), the court held:
A starting point in this review of the law of waiver and
estoppel is the authorities which hold that the estoppel
principle generally has no application to transactions which
are forbidden by statute or ordinance or which are contrary
to public policy. State ex rel. Schwartz v. City of Hialeah, 156
So. 2d 675 (Fla. 3d DCA 1963); Confederation Life Ass'n v.
Conte, 254 So.2d 45 (Fla. 3d DCA 1971), quashed on other
grounds, 272 So.2d 130, cert. denied, 410 U.S. 959, 93
S.Ct. 1422, 35 L.Ed.2d 693. Estoppel is an equitable
doctrine which is applied only where to refuse its application
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Submitted into the public
record in connection with
item D1.3 on 04/24/14
City Clerk
would be virtually to sanction the perpetration of a fraud.
McAllister Enterprise Inc. v. McAllister Hotel, Inc., 219 So.2d
114 (Fla. 3d DCA 1969).
In State ex rel. Schwartz v. City of Hialeah, 156 So. 2d 675 (Fla. 3d DCA 1963),
the court stated:
No clear legal duty appears on the municipality requiring it to
issue a beverage license to the relator but, to the contrary,
the record affirmatively discloses that the City would be in
violation of its own ordinances prohibiting the issuance of an
alcoholic beverage license within 1,500 feet of a church.
Counsel for the appellant has also urged the doctrine of
estoppel as being applicable in the instant case, even
though it is conceded that to issue the license in question
would violate the ordinances of the municipality. The
Supreme Court of Florida has held that the doctrine of
estoppel is not applicable in transactions which are forbidden
by statute or which are contrary to public policy. See:
Montsdoca v. Highlands Bank & Trust Co., 85 Fla. 158, 95
So. 666. If the doctrine of estoppel is not applicable to
transactions which are forbidden by statute, it should not be
applicable to transactions or matters which are prohibited by
municipal ordinances. This rule, applicable to prohibitory
ordinances, would not necessarily be applicable to
ordinances wherein the officials of a municipality had
discretion in exercising their authority."
See also, Dade County v. Gayer, 388 So. 2d 1292, 1294 (Fla. 3d DCA 1980) (court held
that doctrine of equitable estoppel could not be asserted against county to sanction acts
which were prohibited by zoning regulations; "While at first blush it seems that the
application of the rule may be harsh, it would be inconceivable that public officials could
issue a permit, either inadvertently, through error, or intentionally, by design, which
would sanction a violation of an ordinance adopted by the legislative branch of the
government. Only the duly constituted members of the Metropolitan Dade County
Commission enjoy that prerogative and then only in accordance with established
procedure.").
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