State v. Little, 104 So. 3d 1263

The state appeals a trial court order dismissing a concealed weapons charge against Little.
The trial court held Little’s union hall parking lot fell within the 790.25(3)(n) place of business exception.
Police arrested Little in the union hall parking lot for carrying a concealed firearm without a permit.
Little, an elected financial secretary, purportedly provided security at the union hall and its parking lot.
The state did not traverse Little’s Rule 3.190(c)(4) motion; the court granted the motion after a hearing.
The court affirmed the dismissal, ruling Little fell within the 790.25(3)(n) exception.

Issue	Plaintiff's Argument	Defendant's Argument	Held
Whether a union hall qualifies as a place of business under 790.25(3)(n).	Little’s role as union secretary does not make the union hall his place of business.	Unions are business organizations and the hall where Little performed duties is his place of business.	Yes; the union hall falls within the 790.25(3)(n) place-of-business exception.

Peoples v. State, 287 So.2d 63 (Fla. 1973) (place-of-business exception consistent with legislative policy)
State v. Commons, 592 So.2d 317 (Fla. 3d DCA 1991) (place of business can include premises where the individual is employed)
Brook v. State, 999 So.2d 1093 (Fla. 5th DCA 2009) (place of business exception during non-working hours)
McCall v. State, 23 So.2d 492 (Fla. 1945) (place of business defined as location where business is transacted)
Hill v. State, 19 So.2d 857 (Fla. 1944) (unions as business organizations)
Am. Fed. of Musicians, Local 806 v. City of West Palm Beach, 179 So.2d 134 (Fla. 2d DCA 1965) (labor unions are essentially business organizations)
Standard Accident Ins. Co. v. Hoage, 66 F.2d 275 (D.C.Cir. 1933) (supports view unions are business organizations)
Kasischke v. State, 991 So.2d 803 (Fla. 2008) (statutory construction favors defendant when ambiguity)
Santiago v. State, 77 So.3d 874 (Fla. 4th DCA 2012) (statutory interplay between 790.01 and 790.25)