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.
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