City of Fort Lauderdale v. June Dhar, 185 So. 3d 1232

Dollar Rent A Car's vehicle was photographed running a red light; Dollar received a Notice of Violation and identified June Dhar as the short-term renter via affidavit, so Dhar was later issued a uniform traffic citation.
Under § 316.0083(1) (2012), the registered owner/long-term lessee receives an initial $158 Notice of Violation that preserves anonymity and avoids court fees; if unpaid the owner receives a citation.
If an owner files an affidavit naming the actual driver, the named driver may then be issued a uniform traffic citation (a less favorable outcome than receiving the $158 notice).
Short-term renters (like Dhar) are not listed as registrants and therefore cannot receive the initial $158 Notice of Violation; they are identified only after an owner’s affidavit and then face a citation.
Dhar moved to dismiss, arguing the statute’s scheme treated short-term renters unequally (violating equal protection and due process), and the trial court and Fourth District agreed and dismissed the citation.
The Florida Supreme Court, reviewing de novo, affirmed: the 2012 statutory scheme irrationally discriminated against short-term renters and was unconstitutional as applied to Dhar (the statute was later amended in 2013 to address this issue).

Issue	Plaintiff's Argument	Defendant's Argument	Held
Whether § 316.0083(1) (2012) violated equal protection as applied to short-term renters	Dhar: short-term renters are similarly situated to owners/lessees but denied the $158 notice and anonymity, so statute irrationally discriminates	City: statute rationally differentiates based on registration records and administrative convenience	Court: statute lacked a rational basis for treating short-term renters differently; violated equal protection
Whether driving is a fundamental right triggering strict scrutiny	Dhar: (implicit) unequal treatment implicates fundamental fairness	City: regulation of traffic enforcement does not implicate a fundamental right	Court: driving is not a fundamental right; rational-basis review applies
Burden of proof for showing lack of rational basis	Dhar: challenger bears burden to show no rational relationship to legitimate purpose	City: (implicit) statute presumed constitutional; challenger must overcome presumption	Court: applied rational-basis test and found Dhar met burden to show classification lacked rational relation
Remedy and scope of decision	Dhar: seek dismissal of citation as statute invalid as applied	City: sought reversal and upheld statute	Court: held § 316.0083 (2012) unconstitutional as applied to short-term renters; affirmed DCA and remanded

City of Miami v. McGrath, 824 So. 2d 143 (de novo review of statute constitutionality)
Davis v. State, 142 So. 3d 867 (mixed questions: defer to trial court on facts, de novo on constitutional issues)
Henry v. State, 134 So. 3d 938 (same two-step standard for mixed questions)
Connor v. State, 803 So. 2d 598 (articulating standard for mixed questions of law and fact)
Crist v. Ervin, 56 So. 3d 745 (presumption of constitutionality; construe legislation to effect constitutional outcome when possible)
Fla. Dep’t of Revenue v. City of Gainesville, 918 So. 2d 250 (legislative acts accorded presumption of constitutionality)
Level 3 Commc’ns, LLC v. Jacobs, 841 So. 2d 447 (rational-basis standard explained for non-fundamental rights)
Lite v. State, 617 So. 2d 1058 (driving not a fundamental right)