City of Panama City, Florida v. Bambi's Doll House, Inc.

The First DCA reversed the trial court's ruling that Panama City's Ordinance No. 3058 — which defined "change of ownership" to include any stock transfer in a corporation owning a sexually oriented business — was void for failure to use the heightened notice procedures of section 166.041(3)(c), Florida Statutes. The court held that the Legislature's 1995 amendment replaced the old "substantially affects land use" test with a bright-line standard limited to ordinances changing the "actual list" of permitted/conditional/prohibited uses or the "actual zoning map designation," and an ordinance merely clarifying when a nonconforming use loses its privilege does not meet that threshold. The court affirmed, however, that a 100% stock sale of the corporate owner of the business was not a "change of ownership" of the business under the plain pre-Ordinance code language, and remanded for the trial court to adjudicate Appellee's remaining challenges to Ordinance No. 3058.

Florida Court Tracker provides summaries of publicly available court opinions for informational and research purposes only. This is not legal advice and does not create an attorney–client relationship. Always verify holdings against the official opinion.