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South Florida Cargo Carriers Ass'n v. State, Board of Pilot Commissioners

Citations: 627 So. 2d 597; 1993 Fla. App. LEXIS 12273; 1993 WL 499237Docket: No. 93-3244

Court: District Court of Appeal of Florida; December 6, 1993; Florida; State Appellate Court

Narrative Opinion Summary

The case involves a petition by South Florida Cargo Carriers Association, Inc. and Florida Caribbean Cruise Association, Inc. against the Board of Pilot Commissioners, seeking a writ of mandamus or prohibition to compel the board to refer their petitions for pilotage rate changes to the Division of Administrative Hearings (DOAH). The petitioners argued that the current rates were arbitrary and based on unsound financial reports and sought immediate administrative hearings. The court denied the petition, ruling that the Board was correctly adhering to procedures under the Florida Administrative Procedure Act and had not yet denied the petitioners' requests. The court emphasized that formal hearings at DOAH are contingent upon the board's notice of intended agency action regarding rate changes. The court noted that the proceedings were governed by chapter 21SS of the Florida Administrative Code, and the claims were premature, as no actions had been taken by the board to warrant a DOAH referral. Thus, the petition was denied, with concurrence from the judges involved, as the petitioners misunderstood the procedural requirements under chapter 120 of the Florida Statutes.

Legal Issues Addressed

Administrative Procedure Act - Formal Hearings

Application: The court clarified that a formal hearing through the Division of Administrative Hearings (DOAH) is contingent upon the Board of Pilot Commissioners' notice of intended agency action.

Reasoning: The court cited section 120.57(1)(a)1 of the Florida Statutes, which indicates that a DOAH hearing officer is responsible for conducting formal hearings, and emphasized that the board must first provide a notice of intended agency action regarding the rate changes before the petitioners could seek a DOAH referral.

Mandamus and Prohibition

Application: The court denied the petition for a writ of mandamus or prohibition, determining that the Board of Pilot Commissioners was correctly following procedural requirements under the Florida Administrative Procedure Act.

Reasoning: The court denied the petition, determining that the Board of Pilot Commissioners was proceeding correctly under the Florida Administrative Procedure Act and that it had not yet denied the petitioners' requests.

Prematurity of Claims

Application: The court found that the petitioners' claims were premature as the board had not yet acted on their request for a rate change.

Reasoning: The petitioners were found to be misunderstanding the nature of the chapter 120 process, which is not triggered until after the board acts on their request for a rate change.