City of Hollywood, a political subdivision of the State of Florida v. Eric Arem, 154 So. 3d 359

City of Hollywood outsourced red light camera program to private vendor ATS; ATS reviews images and only after vendor determines a violation does information reach the Traffic Infraction Enforcement Officer (TIEO).
TIEO clicks the Accept button to authorize enforcement; the vendor prints and mails the notice and transmits a replica of citation data to the court.
Trial court dismissed the citation, finding the statutes require issuance by a TIEO, not a private vendor, and that outsourcing violated Florida law.
The court held Florida law strictly construes Chapter 316 to prevent local governments from delegating citation issuance to private entities.
The court answered the certified questions by (1) prohibiting private delegation of citation issuance, (2) not addressing the delegation of data transmission to private entities, and (3) affirming dismissal as the remedy for improper delegation.

Issue	Plaintiff's Argument	Defendant's Argument	Held
Authority to delegate citation issuance to a private vendor	City argues statute permits review and delegation	Arem argues only law enforcement/TIEOs may issue citations	No; private delegation not authorized
Delegation of electronic transmission to a private entity	City implies delegation permissible under statute	Statutes require TIEOs to issue and transmit citations	Not addressed by the court
Remedy for improper delegation	Citation should not be voided	Deleterious to enforcement if not dismissed	Dismissal is appropriate remedy

Maddox v. State, 923 So.2d 442 (Fla. 2006) (uniform traffic control purpose; statutory strict construction)
Holly v. Auld, 450 So.2d 217 (Fla. 1984) (statutory interpretation and intent)
State v. Smith, 584 So.2d 145 (Fla. 2d DCA 1991) (uniform statewide traffic control regime and limits on local authority)
County of Volusia v. City of Deltona, 925 So.2d 340 (Fla. 5th DCA 2006) (outsourcing/ delegation concerns in traffic enforcement)