Jefferson County Kennel Club, Inc. v. Florida Gaming Control Commission
The First DCA affirmed summary judgment for the Florida Gaming Control Commission, rejecting JCKC's constitutional challenges to the permit-revocation provision of the 2021 Gaming Compact legislation. The court held § 550.054(9)(c) is not a special law, survives rational-basis due process review, and did not impair any enforceable contract because an unexecuted letter of intent is not a binding contract.
Key facts
- In 2021 the Florida Legislature passed Senate Bill 8-A revising the Pari-mutuel Wagering Act (ch. 550) to implement the new Seminole Tribe Gaming Compact, including § 550.054(9)(c), which mandated revocation of any pari-mutuel wagering permit held by an entity that was not licensed and operating in fiscal year 2020-2021.
- Jefferson County Kennel Club (JCKC) had not operated in FY 2020-2021 and faced permit revocation; it sued the Florida Gaming Control Commission, alleging the revocation statute was an unconstitutional special law, violated due process, and impaired contracts.
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Holdings
- A statute that appears to operate on a closed class of entities is not an unconstitutional special law under Art. III, § 11(a)(12) of the Florida Constitution if it fits within a broader…
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Why it matters
This opinion is instructive for practitioners challenging regulatory statutes affecting industry permits or licenses. It reinforces that gaming permits—and likely analogous privileges—are not constitutionally protected… — full analysis with a trial
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