The City of Miramar, Florida, et al. v. Florida State Lodge Fraternal Order of Police, Inc., et al.
The Fourth DCA reversed a declaratory judgment holding that public employee labor arbitration hearings must be open to the public under Florida's Sunshine Law (section 286.011(1)). The court held that a sole arbitrator is neither a 'board' nor 'commission' within the plain meaning of the Sunshine Law, and that an individual employee's grievance arbitration hearing is not 'collective bargaining negotiations' under section 447.605(2). The decision draws a clear textual line between the negotiation phase of collective bargaining — which must be conducted in public — and the administration and adjudication of grievances under an executed CBA.
Key facts
- A Miramar police officer (Braga) was disciplined by the Police Department and the union (Fraternal Order of Police) filed a grievance under the Collective Bargaining Agreement; the city denied the grievance and the union demanded arbitration.
- The parties disagreed about whether the arbitration hearing should be open or closed to the public; the union demanded other union members be allowed to attend, while the city refused to proceed with non-parties present.
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Holdings
- Florida's Sunshine Law, section 286.011(1), applies only to meetings of 'boards or commissions'; an arbitration proceeding conducted by a sole arbitrator is not a meeting of a 'board' or…
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Why it matters
This decision provides clear guidance for Florida municipalities, public employers, and public employee unions regarding the scope of Florida's Sunshine Law in the context of labor arbitration. Public employers handling… — full analysis with a trial
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