Clay County Education Ass'n v. Clay County School Board
144 So. 3d 708
| Fla. Dist. Ct. App. | 2014Background
- Clay County Education Association (CCEA) requested public records from the Clay County School Board relating to school operations and oversight; some materials were produced but others were withheld.
- CCEA filed a complaint for writ of mandamus and sought an immediate hearing under section 119.11(1), Florida Statutes.
- The trial court issued an alternative writ directing the School Board to file defenses; the School Board filed an unsworn response claiming it had provided the records, could not produce them in the requested format, or that the records did not exist.
- The trial court dismissed CCEA’s complaint based solely on the pleadings, concluding CCEA failed to show a clear legal right to relief.
- CCEA appealed, arguing the dismissal was improper and that the court should have held an evidentiary hearing to resolve factual disputes about possession and existence of records.
Issues
| Issue | Plaintiff's Argument | Defendant's Argument | Held |
|---|---|---|---|
| Whether complaint sufficiently alleged a clear legal right and School Board an indisputable duty under public records law | CCEA: complaint cites Fla. Const. art. I, §24(a) and ch. 119 and alleges requested items are public records in Board custody | School Board: asserted records were already produced, not available in requested format, or did not exist | Court: complaint states a prima facie case; dismissal improper |
| Whether trial court could dismiss based solely on pleadings when factual disputes exist | CCEA: factual disputes (possession/existence) require evidentiary resolution and immediate hearing under §119.11(1) | School Board: relied on unsworn responsive assertions to support dismissal | Court: factual disputes cannot be resolved on motion to dismiss; court erred in failing to hold evidentiary hearing |
| Whether the trial court was required to set an immediate hearing under §119.11(1) | CCEA: statute mandates an immediate, prioritized hearing when enforcing public records law | School Board: did not contest the statute’s need for hearing but relied on its responsive claims | Court: statute requires immediate hearing; remand for same |
| Proper remedy where petition and answer raise disputed facts | CCEA: request for in-court factfinding and possible in camera inspection | School Board: implied denial of possession sufficed to dismiss | Court: remand for evidentiary hearing and further proceedings (including in camera inspection if necessary) |
Key Cases Cited
- Walker v. Ellis, 989 So.2d 1250 (Fla. 1st DCA) (standard of review for dismissal of mandamus action)
- Felder v. State, Dep’t of Mgmt. Servs., Div. of Retirement, 993 So.2d 1031 (Fla. 1st DCA) (motion to dismiss tests legal sufficiency; courts accept plaintiff’s allegations)
- Miller v. Nelms, 966 So.2d 437 (Fla. 2d DCA) (pleading standards on motion to dismiss)
- Polley v. Gardner, 98 So.3d 648 (Fla. 1st DCA) (elements for mandamus: clear right and indisputable duty)
- Johanson v. State, 872 So.2d 387 (Fla. 4th DCA) (reversed denial of mandamus where state’s unsworn claim of non-possession required evidentiary hearing and possible in camera review)
- Radford v. Brock, 914 So.2d 1066 (Fla. 2d DCA) (when petition and answer raise factual dispute about possession, trial court must resolve on evidence)