Dean K. Matt v. State of Florida, et al., SC2024-0990

Background

The University Park Recreation District (UPRD) is a special recreation district created in 2018 to purchase, maintain, and improve the University Park Country Club and related recreational facilities. 1
A 2019 bond issue was authorized by referendum and validated, and the first supplemental indenture contained bracketed section 5.04 language suggesting no further bond issues. 2
Matt bought a home in the UPRD in 2021, expected no future bond issues, and opposed the UPRD’s proposed 2024 bond issue based on section 5.04 and special-benefit objections. 3
Before the 2024 referendum, the Board adopted Resolution 2024-08 to clarify that the bracketed language was never intended to bind the district and to authorize a second supplemental indenture. 4
The 2024 referendum passed, the UPRD filed for bond validation, and at the hearing the court heard evidence that the project would specially benefit UPRD properties and that assessments would be fairly apportioned. 5
The circuit court validated the bonds, and Matt appealed, also challenging the judge’s handling of his unsworn disqualification motion and claimed due-process defects. 6

Issues

Issue	Plaintiff's Argument	Defendant's Argument	Held
Did the UPRD have authority to issue the 2024 bonds? 7	Matt said section 5.04 barred any new bonds until cured.	UPRD said it had statutory authority and had cured any ambiguity before the referendum.	Yes; the UPRD had authority, and section 5.04 did not bar the issue. 8
Did the 2024 assessments satisfy special-benefit requirements? 9	Matt said UPRD failed to prove the assessments exceeded the burden of debt.	UPRD relied on legislative findings, the methodology report, and expert testimony showing logical property benefits.	Yes; competent evidence supported special benefit and fair apportionment. 10
Was Matt denied due process by the hearing and disqualification ruling? 11	Matt claimed bias, ignored evidence, and premature judgment before review of his stay motion.	UPRD argued Matt received notice and a hearing, and his disqualification motion was defective and untimely.	No; due process was satisfied and the disqualification motion was properly denied. 12

Key Cases Cited

Florida Bankers Ass'n v. Florida Development Finance Corp., 176 So. 3d 1258 (Fla. 2015) (bond validation review is limited; factual findings reviewed for competent, substantial evidence 13)
Keys Citizens for Responsible Government, Inc. v. Florida Keys Aqueduct Authority, 795 So. 2d 940 (Fla. 2001) (validation proceedings settle basic validity and repose disputes affecting the bonds 14)
State v. Sunrise Lakes Phase II Special Recreation Dist., 383 So. 2d 631 (Fla. 1980) (recreation districts are financing vehicles and may issue bonds 15)
Citizens Advocating Responsible Environmental Solutions, Inc. v. City of Marco Island, 959 So. 2d 203 (Fla. 2007) (special-assessment review uses a two-pronged special-benefit and apportionment test 16)
City of Winter Springs v. State, 776 So. 2d 255 (Fla. 2001) (special assessments must both confer special benefit and be fairly apportioned 17)
City of Boca Raton v. State, 595 So. 2d 25 (Fla. 1992) (no parcel-by-parcel dollar itemization is required; legislative findings receive deference 18)
Morris v. City of Cape Coral, 163 So. 3d 1174 (Fla. 2015) (special benefit exists where services have a logical relationship to the property and may be qualitatively described 19)
Lake County v. Water Oak Management Corp., 695 So. 2d 667 (Fla. 1997) (property may specially benefit from services that enhance value and lower insurance costs 20)
Cafeteria & Restaurant Workers Union v. McElroy, 367 U.S. 886 (U.S. 1961) (procedural due process begins with the nature of the interest and government function at stake 21)