Detzner v. Anstead
The Florida Supreme Court reversed a circuit court judgment that had granted quo warranto relief striking CRC-proposed Amendments 7, 9, and 11 from the 2018 ballot. The Court held that quo warranto was the wrong vehicle because petitioners conceded the Secretary of State had authority to place amendments on the ballot and did not allege he exceeded that authority; merits challenges to proposed amendments must be brought by complaint for declaratory and injunctive relief. On the merits, the Court held that CRC proposals are not subject to the single-subject rule and may bundle unrelated measures without violating section 101.161(1) or the First Amendment.
Key facts
- Secretary of State Detzner and CRC sought review after a circuit court granted a quo warranto petition striking three CRC-proposed constitutional amendments (7, 9, and 11) from the 2018 ballot.
- Petitioners challenged the amendments' validity on grounds including violation of the single-subject rule, but framed their challenge as a petition for writ of quo warranto rather than a complaint for declaratory and injunctive relief.
- +2 more key facts with a free trial
Why it matters
The decision supplies a crisp, citable rule on the limits of quo warranto: it tests only whether an officer exceeded authority, not the substantive legality of the officer's action, with merits challenges channeled into… — full analysis with a trial
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