Background
- City of Fort Walton Beach seeks a ruling on whether Fla. Stat. §166.0495 allows interlocal police services agreements only with adjoining municipalities within the same county.
- Statute authorizes interlocal agreements with adjoining municipalities within the same county to provide law enforcement services, but the opinion focuses on interpreting the text.
- Legislative history and committee debates indicate the act targets adjoining communities within the same county.
- The title and legislative history are used to illuminate legislative intent, though not determinative.
- A grammatical-interpretation rule is applied to construe the phrase 'adjoining municipality or municipalities within the same county' as requiring both adjoining status and same-county location.
- Holding: §166.0495 permits interlocal law enforcement agreements only with municipalities that both adjoin and are within the same county.
Issues
| Issue | Plaintiff's Argument | Defendant's Argument | Held |
|---|---|---|---|
| Does §166.0495 authorize agreements only with adjoining municipalities within the same county? | Fort Walton Beach argues for the broad, statutory grant. | Attorney General reads statute to require adjoining and same-county criteria. | Yes; only adjoining municipalities within the same county may be parties. |
Key Cases Cited
- Parker v. State, 406 So. 2d 1089 (Fla. 1981) (statutory intent may be inferred from title and legislative history)
- Finn v. Finn, 312 So. 2d 726 (Fla. 1975) (title may define scope of act)
- Berger v. Jackson, 23 So. 2d 265 (Fla. 1945) (title of act may be considered in determining intent)
- Speights v. State, 414 So.2d 574 (Fla. 1st DCA 1982) (title as aid in determining Legislative intent)
- Reynolds v. State, 842 So.2d 46 (Fla. 2002) (legislative intent guides statutory construction)
- Jarrett v. State, 926 So.2d 429 (Fla. 2d DCA 2006) (jurisdictional/record considerations in interlocal arrangements)