Walter E. Headley, Jr. v. City of Miami, Florida, 215 So. 3d 1

Miami Lodge No. 20 (the Union) and City of Miami had a collective bargaining agreement covering 2007–2010; in July–August 2010 the City declared a "financial urgency" under section 447.4095 and adopted unilateral changes to wages, pensions, and other economic terms.
The City presented evidence of a large budget deficit (~$140 million on a $500 million budget), hiring freezes, layoffs, and other austerity measures; the Union proposed alternatives (tax increases, non‑union layoffs, furloughs, etc.).
The Union filed an unfair labor practice charge with the Public Employees Relations Commission (PERC), arguing the City improperly invoked section 447.4095 and prematurely altered the CBA without completing impasse procedures.
PERC and the First District upheld the City’s invocation of the statute and allowed implementation after "impact bargaining" (notice and opportunity to bargain), concluding the City need only show other measures were unreasonable or inadequate.
The Fourth District reached the opposite conclusion, applying Chiles and holding the employer must demonstrate funds are unavailable from any other possible reasonable source.
The Florida Supreme Court granted review, adopted the Fourth District’s view, and quashed the First District insofar as it allowed unilateral changes without satisfying Chiles or completing impasse procedures.

Issue	Plaintiff's Argument (Headley/Union)	Defendant's Argument (City)	Held
1. Standard to justify unilateral modification under §447.4095 — must employer show no other reasonable funding source exists?	City must show funds are available from no other possible reasonable source before modifying a CBA.	Statute requires only that other potential cost‑saving measures or funding sources be unreasonable or inadequate; full Chiles test is not required.	Court holds Chiles standard applies: employer must demonstrate no other reasonable alternative means/funds exist (i.e., funds unavailable from any other possible reasonable source).
2. Timing/procedure — may a local government implement changes immediately after declaring financial urgency (after "impact" bargaining), or must it complete §447.403 impasse resolution before changes take effect?	Changes cannot take effect until parties complete the impasse resolution process (special magistrate, post‑hearing steps).	Language "negotiate the impact" contemplates impact bargaining (notice + opportunity) and permits implementation after that limited negotiation.	Court holds unilateral implementation is not permitted before completing the §447.403 impasse process; the statute requires pursuing impasse procedures.

Chiles v. United Faculty of Florida, 615 So.2d 671 (Fla. 1993) (establishes strict scrutiny—government may impair collective‑bargaining obligations only for compelling interest and only if no other reasonable alternative sources exist)
Hillsborough Cty. Govtl. Emps. Ass’n v. Hillsborough Cty. Aviation Auth., 522 So.2d 358 (Fla. 1988) (collective bargaining is a fundamental right requiring compelling state interest to abridge)
Holly v. Auld, 450 So.2d 217 (Fla. 1984) (statutes given plain and obvious meaning; no need for construction if unambiguous)
Yamaha Parts Distribs., Inc. v. Ehrman, 316 So.2d 557 (Fla. 1975) (strong protection against contract impairment)
United Faculty of Florida v. Public Employees Relations Commission, 898 So.2d 96 (Fla. 1st DCA 2005) (courts should defer to PERC’s expertise on statutory interpretation unless agency error)