Alachua County, etc. v. Clovis Watson, Jr., etc.
333 So. 3d 162
| Fla. | 2022Background
- Alachua County sued Sheriff Clovis Watson, Jr. after the Sheriff (through predecessor) transferred about $840,000 between object-level budget categories in 2016 without Board approval (≈ $700,000 from jail personnel to operating and capital outlay).
- Dispute centers on whether sheriffs may unilaterally transfer appropriations at the object level under chapters 30 and 129, Fla. Stat.; subobject-level control is more clearly reserved to sheriffs.
- Trial court held the Sheriff could make object-level transfers without county approval; the First District affirmed, relying on sheriffs’ independence (§30.53), the “lame duck” clause (§129.06(5)), and Weitzenfeld v. Dierks.
- Supreme Court reviewed de novo whether the statutes, read together, permit object-level transfers by a sheriff without following the county budget-amendment process in chapter 129.
- The Court held the Legislature’s scheme requires sheriff to follow the chapter 129 amendment process for object-level transfers; the Sheriff failed to do so, so the object-level transfers here required Board approval.
Issues
| Issue | Plaintiff's Argument (Alachua) | Defendant's Argument (Sheriff) | Held |
|---|---|---|---|
| May a sheriff transfer funds between object-level appropriations without county approval? | County: No; once budget adopted, object-level appropriations are fixed and changes must follow §129.06 amendment process. | Sheriff: Yes; §30.53 preserves sheriff independence over spending, so object-level transfers need not be approved except as limited by the lame-duck clause. | Held: No; sheriff must follow chapter 129 amendment procedures to transfer between objects. |
| Does the lame-duck prohibition in §129.06(5) imply other sheriffs may transfer funds freely? | County: No; the lame-duck clause is a specific limitation, not a grant of general transfer power to non-lame-duck officers. | Sheriff: Yes; expressio unius est exclusio alterius means the statute’s specific prohibition on lame-duck officers implies others are not prohibited. | Held: The Court rejects that inference—the lame-duck clause is limited and does not nullify chapter 129’s amendment framework. |
| Does Weitzenfeld v. Dierks control to allow reallocations here? | County: Weitzenfeld addressed subobject-level allocations under an earlier statute and does not authorize object-level reallocations under the current statutory scheme. | Sheriff: Weitzenfeld supports preserving sheriff budgetary independence against county reallocation. | Held: Weitzenfeld is not overruled but is distinguishable; current statutes allocate more detail and require following chapter 129 for object-level changes. |
Key Cases Cited
- Weitzenfeld v. Dierks, 312 So. 2d 194 (Fla. 1975) (prior case limiting county intrusion into sheriff functions at subobject level)
- Niz-Chavez v. Garland, 141 S. Ct. 1474 (U.S. 2021) (textualist approach: interpret statute by ordinary meaning and whole-text context)
- Moonlit Waters Apartments, Inc. v. Cauley, 666 So. 2d 898 (Fla. 1996) (discussion of expressio unius canon)
- Pinellas Cnty. v. Nelson, 362 So. 2d 279 (Fla. 1978) (chapter 129 places budget oversight duty on board of county commissioners)
- GTC, Inc. v. Edgar, 967 So. 2d 781 (Fla. 2007) (statutory-interpretation review is de novo)