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Hialeah Racing Ass'n v. Department of Business & Professional Regulation, Division of Pari-Mutuel Wagering

Citations: 907 So. 2d 1235; 2005 Fla. App. LEXIS 10788; 2005 WL 1631116Docket: No. 3D04-3001

Court: District Court of Appeal of Florida; July 13, 2005; Florida; State Appellate Court

Narrative Opinion Summary

The case involves Hialeah Racing Association, LLC's appeal against the Department of Business and Professional Regulation's final order revoking its pari-mutuel wagering thoroughbred racing permit and denying its 2003-2004 annual racing license application. The Department's decision was based on Hialeah Racing's failure to run scheduled races due to financial constraints, which does not qualify as just cause under Florida Statutes Section 550.01215(4). The court affirmed the Department's order, as it was supported by competent and substantial evidence, and reiterated that an agency's interpretation of its statutes should not be overturned unless clearly erroneous. The court held that financial hardship does not constitute a valid statutory exception for non-operation, affirming the revocation of Hialeah Racing's permit. The court also addressed and dismissed the appellant's remaining arguments as meritless, resulting in the conclusion that the Department's order should stand. This decision underscores the necessity for compliance with statutory operation requirements unless hindered by uncontrollable events.

Legal Issues Addressed

Consequences of Failure to Operate as Scheduled

Application: Failure to operate scheduled races without statutory justifications like uncontrollable events leads to revocation of permits.

Reasoning: The ruling reinforces that failure to operate as specified can lead to penalties unless caused by uncontrollable events like fire or war.

Justification for Non-Operation of Scheduled Races

Application: Economic motivations, such as financial constraints, do not meet the statutory exceptions for failing to run scheduled races.

Reasoning: The Department found that Hialeah Racing’s decision to not run scheduled races was economically motivated, which does not qualify as a statutory exception to operation requirements.

Requirements for Operating Under Florida Statutes Section 550.01215(4)

Application: Financial hardship does not qualify as just cause for failing to operate a racing schedule, impacting Hialeah Racing's permit status.

Reasoning: Specifically, Florida Statutes Section 550.01215(4) states that financial hardship alone does not constitute just cause for failing to operate.

Standard of Review for Agency Decisions

Application: The court will affirm an agency's interpretation of statutes unless it is clearly erroneous, thus supporting the Department's decision to revoke the permit.

Reasoning: The court emphasized that it would not overturn an agency’s interpretation of the statutes it administers unless that interpretation is clearly erroneous.