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Seminole Tribe of Florida v. State Department of Business Regulation, Division of Alcoholic Beverages & Tobacco

Citations: 496 So. 2d 193; 11 Fla. L. Weekly 2146; 1986 Fla. App. LEXIS 10116Docket: No. BK-272

Court: District Court of Appeal of Florida; October 13, 1986; Florida; State Appellate Court

Narrative Opinion Summary

Appellants contested proposed Fla.Admin. Code Rule 7A-10.26, claiming it represented an invalid exercise of delegated legislative authority and exceeded the scope of its enabling legislation. The hearing officer determined that the proposed rule only provided a clearer definition than the existing statutory language and did not overstep statutory authority. The court affirmed this conclusion. Proposed Rule 7A-10.26 enhances the previous rule's definition of Seminole Indians, introduces additional record-keeping and documentation requirements, and stipulates that relevant sales may occur only on reservation or trust lands. The primary enabling statute is 210.05(5), Fla.Stat. The provisions of the proposed rule are deemed reasonable interpretations of the statutory language and align with the legislative intent. The decision was affirmed, with Judges Joanos and Nimmons concurring.

Legal Issues Addressed

Authority to Define Terms in Administrative Rules

Application: The court found that the proposed rule provided a clearer definition than the existing statutory language, which was within the bounds of its enabling statute.

Reasoning: The hearing officer determined that the proposed rule only provided a clearer definition than the existing statutory language and did not overstep statutory authority.

Invalid Exercise of Delegated Legislative Authority

Application: The appellants challenged the proposed rule on the grounds that it overstepped its enabling legislation, but the court determined that the rule did not exceed statutory authority.

Reasoning: Appellants contested proposed Fla.Admin. Code Rule 7A-10.26, claiming it represented an invalid exercise of delegated legislative authority and exceeded the scope of its enabling legislation.

Judicial Review of Administrative Rulemaking

Application: The court's role in reviewing the administrative rulemaking process was to ensure the rule aligned with statutory authority and legislative intent, which it affirmed in this case.

Reasoning: The decision was affirmed, with Judges Joanos and Nimmons concurring.

Reasonableness and Legislative Intent in Rulemaking

Application: The provisions of the proposed rule were considered reasonable interpretations of the statutory language and were consistent with legislative intent, leading to the court's affirmation of the rule.

Reasoning: The provisions of the proposed rule are deemed reasonable interpretations of the statutory language and align with the legislative intent.