Fraternal Order of Police, Miami Lodge 20 v. City of Miami, 243 So. 3d 894

In June 2010 the City of Miami declared a "financial urgency" and invoked section 447.4095, Fla. Stat., triggering a 14‑day negotiation period and potential impasse procedures.
Fraternal Order of Police, Miami Lodge 20 (FOP) filed a facial challenge to section 447.4095, arguing vagueness, substantive due process, and equal protection violations.
The trial court granted summary judgment for the City; the Third District Court of Appeal affirmed.
The Florida Supreme Court accepted review to resolve an asserted district‑court conflict and to determine the statute’s constitutionality.
The Court limited review to the statute’s text (facial challenge), applying the presumption of constitutionality and de novo review of legal questions.

Issue	Plaintiff's Argument	Defendant's Argument	Held
Vagueness: Is "financial urgency" too vague?	Term undefined; cities get unfettered discretion to modify agreements.	Legislature may leave term to agency expertise (PERC); not every term must be statutorily defined.	Not unconstitutionally vague; deferral to PERC interpretation permissible.
Substantive due process: Does the statute unreasonably infringe fundamental rights?	Statute infringes right to contract/collective bargaining without narrow tailoring.	Statute codifies strict scrutiny; requires dire financial condition and necessity to modify CBA.	No violation; statute satisfies strict scrutiny as previously construed.
Equal protection: Does statute impermissibly discriminate?	Treats public employees differently than private employees.	Public bargaining differs because it regulates public funds; distinguishing is legitimate.	No violation; differences are justified and statute meets strict scrutiny when implicated.
Scope of review: May Court evaluate statutory application or only text?	FOP argued facial invalidity — sought broad invalidation.	City urged deference and that PERC can define scope in applications.	Court confined to facial review and found statute constitutional as written.

Scott v. Williams, 107 So. 3d 379 (Fla. 2013) (standard of review for constitutional questions)
Abdool v. Bondi, 141 So. 3d 529 (Fla. 2014) (limits on facial challenges)
Florida Dep’t of Revenue v. Howard, 916 So. 2d 640 (Fla. 2005) (presumption of constitutionality and construction to effect validity)
Samples v. Florida Birth-Related Neurological Injury Comp. Ass’n, 114 So. 3d 912 (Fla. 2013) (void-for-vagueness standard)
In re Advisory Opinion to Governor, 509 So. 2d 292 (Fla. 1987) (legislative delegation and permissible generality)
Headley v. City of Miami (Headley Miami Lodge), 215 So. 3d 1 (Fla. 2017) (construction of "financial urgency" and strict scrutiny framework)
Chiles v. United Faculty of Florida, 615 So. 2d 671 (Fla. 1993) (strict scrutiny for impairments of contract/collective bargaining)
State v. Hagan, 387 So. 2d 943 (Fla. 1980) (failure to define a term does not automatically render a statute vague)