Sanchez v. Miami-Dade County
Plaintiff shot at a birthday party in a county park sued Miami-Dade County for negligent security; the Third District held sovereign immunity barred the claim because it attacked the County's discretionary allocation of off-duty police officers. The Supreme Court, after granting conflict jurisdiction based on City of Belle Glade v. Woodson, dismissed review, holding the conflict issue (conflation of duty and sovereign immunity) was already settled by Pollock and Wallace v. Dean, and that the petitioner improperly advanced a new theory of liability (failure to monitor and enforce park rental rules) never presented below.
Key facts
- Plaintiff was shot at a birthday party in a Miami-Dade County park and sued the County alleging negligent security in the deployment of off-duty police officers.
- The trial court granted summary judgment for Miami-Dade County; the Third District affirmed, holding sovereign immunity barred the negligent security claim as it attacked the County's discretionary allocation of police resources.
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Why it matters
The opinion leaves standing the Third District's holding that negligent-security claims premised on a government's failure to deploy police officers are barred by sovereign immunity as discretionary planning-level… — full analysis with a trial
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