Matheson v. Miami-Dade County
258 So. 3d 516
| Fla. Dist. Ct. App. | 2018Background
- Miami-Dade County adopted a resolution to sell ~2.79 acres to 0101 Miami Properties (David Beckham’s group) for construction/operation of an MLS stadium and related economic development, for $9,015,000 plus required economic commitments (minimum $175M investment, creation of 50 jobs, training program, small-business participation, etc.).
- Bruce Matheson, owner of nearby property, filed for writ of mandamus and declaratory/injunctive relief, alleging the county was required by §125.35 to sell the land via competitive bidding and that he was ready, willing, and able to bid.
- The county and Miami Properties moved to dismiss, arguing Matheson lacked standing and that §125.045 authorized below‑market conveyances for economic development without following §125.35 bidding procedures.
- The trial court dismissed, finding Matheson had standing but the county had no clear legal duty to competitively bid because §125.045 provided an independent economic‑development authority; the sale qualified as an economic development incentive.
- The appellate court affirmed: Matheson had standing (allegation of ready/willing/able to bid sufficed), but §125.045 is a specific authorization allowing below‑market economic development conveyances that operate as an exception to §125.35’s competitive‑bidding procedure.
Issues
| Issue | Plaintiff's Argument | Defendant's Argument | Held |
|---|---|---|---|
| Standing to challenge county sale | Matheson alleged he was ready, willing, and able to purchase the property and thus had a cognizable interest to challenge bidding | County argued Matheson could not actually build a stadium even with the parcel, so allegation is hollow | Court: Allegation of readiness to bid is sufficient at pleading stage; Matheson had standing |
| Whether §125.35 required competitive bidding for this sale | §125.35’s phrase “any real property” mandates competitive bidding for all county real‑property sales | §125.35 authorizes competitive bidding for sales the board chooses to market that way; it does not override specific statutory exceptions | Court: §125.35 does not impose a blanket mandate; read in context it authorizes competitive bidding but does not preclude exceptions |
| Whether §125.045 permits below‑market, negotiated conveyances for economic development (i.e., exempts such sales from §125.35) | Matheson: Even economic‑development sales must be competitively bid under §125.35; otherwise public bidding protection is eviscerated | County: §125.045 specifically authorizes economic development incentives (including below‑market deeds/leases) and thus operates as an exception to §125.35 bidding requirements | Court: §125.045 is a specific statutory authorization for economic development incentives and harmonizes with chapter 125 as an exception to §125.35; sale qualified under §125.045, so no clear duty to bid |
| Whether the sale here met §125.045’s requirements or risked abuse/corruption | Matheson: Allowing the county to label favored deals as “economic development” invites sweetheart deals and avoids competitive safeguards | County: Chapter 125 sets standards; §125.045 limits economic‑development conveyances to public‑purpose activities and reporting; unlawful deals remain subject to anti‑corruption laws | Court: The transaction’s documented economic commitments satisfied §125.045; statutory and criminal constraints guard against abuse; dismissal affirmed |
Key Cases Cited
- Lopez-Infante v. Union Cent. Life Ins. Co., 809 So. 2d 13 (Fla. 3d DCA 2002) (motion to dismiss reviewed de novo)
- E.A.R. v. State, 4 So. 3d 614 (Fla. 2009) (statutory interpretation reviewed de novo)
- Sosa v. Safeway Premium Fin. Co., 73 So. 3d 91 (Fla. 3d DCA 2011) (standing reviewed de novo)
- Accela, Inc. v. Sarasota County, 901 So. 2d 237 (Fla. 2d DCA 2005) (allegation of readiness to bid sufficient for standing in procurement challenge)
- Fla. Dep’t of Envtl. Prot. v. ContractPoint Fla. Parks, LLC, 986 So. 2d 1260 (Fla. 2008) (whole‑text canon; read subsections in context to avoid isolationist readings)
- Forsythe v. Longboat Key Beach Erosion Control Dist., 604 So. 2d 452 (Fla. 1992) (related statutes should be construed harmoniously)
- Metro. Cas. Ins. Co. v. Tepper, 2 So. 3d 209 (Fla. 2009) (statutory words not to be treated as superfluous)
- Rolling Oaks Homeowner’s Ass’n v. Dade County, 492 So. 2d 686 (Fla. 3d DCA 1986) (chapter 125 competitive‑bidding analysis and recognized statutory exemptions)
- Marriott Corp. v. Metro. Dade Cty., 383 So. 2d 662 (Fla. 3d DCA 1980) (highest and best bid defined as financially most advantageous to community)