Halifax Hospital Medical Center v. State of Florida
Halifax, a hospital special tax district, sought validation of revenue bonds to finance a hospital in Deltona, outside its statutory geographic boundaries, relying on its enabling act and an interlocal agreement with the City of Deltona. The Florida Supreme Court affirmed the denial of bond validation, holding that under chapter 189 a special district is presumed limited to its defined geographic boundary and that any extraterritorial authority must be expressly and unambiguously granted, which Halifax's enabling act did not do. The Court further held the Interlocal Act cannot confer authority the agency could not 'exercise separately.'
Key facts
- Halifax Hospital Medical Center, a special tax district, sought validation of revenue bonds to finance a hospital facility in Deltona, a city located outside Halifax's statutory geographic boundaries.
- Halifax relied on its enabling act and an interlocal agreement with the City of Deltona to claim authority to operate the hospital outside its defined district.
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Why it matters
This is the Florida Supreme Court's definitive statement that special districts are presumptively confined to their geographic boundaries and that interlocal agreements under section 163.01 cannot bootstrap powers an… — full analysis with a trial
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