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Another Fine Mess: Are Non-ad Valorem Special Assessments for Local Government Nuisance Abatement Charges Legally Defensible?

City, County and Local Government

A residential lot on the west coast of Florida is covered in trash, debris, inoperable vehicles, thickets of weeds, and rotting wood; the home on the lot is falling apart. The code violations on the property are so numerous and longstanding that they have accumulated $2.5 million in fines and costs — an impossible sum. The property remains littered with refuse with no immediate remedy in sight.1 On a property in a neighboring city, a tattered blue tarp waves in the breeze from the collapsed roof of a vacant foreclosure home, an eyesore boasting $100,000 in outstanding fines for code violations.2

Across the bay, a small home has nearly vanished behind tons of garbage, and the yard has become a swamp, swarming with vermin, mildew, and insects. The code violations on the property have persisted for 17 years, accruing fines up to $320,000. Local government code enforcement could remedy the problem, but only at an estimated cost to taxpayers of $90,000.3

Such neglected, misused, or abandoned nuisance properties4 create problems for local governments and communities, including neighborhood blight, loss of tax revenue, and increased tax expenditures for cleanup.5 Even if a local code enforcement department is authorized to clean up the mess, it has few reasonable options for recovering costs incurred.6 This creates a conundrum. How does a city or county address public health and welfare concerns created by nuisance properties when presented with limitations on code enforcement and an uphill battle to collect fines and costs imposed on nuisance properties?

One remedy recently adopted or proposed by municipalities across the state is a non-ad valorem special assessment for reimbursement of costs expended in abating chronic nuisances. Such chronic nuisance property ordinances propose that abatement costs be recovered from the violating property owner through the annual property tax bill, using the uniform collection method (UCM) under F.S. §197.3632.7 This appears to be a simple solution to a complex problem. However, there are significant concerns that any local government considering adoption of such a chronic nuisance property ordinance must consider.

This article discusses whether using the UCM to recover costs related to code enforcement — and particularly nuisance abatement — are legally defensible.

Special Assessments as Creative Solutions
A special assessment is a charge “assessed against the property of a particular locality because that property derives some special benefit” from a government service provided in that locale beyond the general benefit accruing to all citizens.8 Counties and cities are authorized to collect special assessments by F.S. §§125.01(r) and 170.01, and through their home rule powers.9

When collected through the UCM, special assessments are subject to the same collection procedures as ad valorem property taxes — including enforcement mechanisms, such as the sale of tax certificates and tax deeds. Thus, use of the tax bill is an attractive option for nuisance abatement cost recovery in that it is both efficient and effective when other attempts to collect on a bill have failed.10

A fairly standard chronic nuisance property ordinance, typical of many around the state reviewed for this article, defines a “nuisance” to include the violation of one or more municipal codes or state statutes. In one such ordinance, the City of Lake Worth seeks to use the UCM to recover costs expended to abate nuisances arising from violation of local ordinances on lot clearing, unsafe or vacant buildings, and noise control, as well as state criminal statutes.11 Similarly, the City of Ft. Meade has an ordinance to recoup the cost of demolishing unsafe structures as special assessments on tax bills.12

Some chronic nuisance ordinances are drafted with a greater focus on criminal, rather than code, violations. For example, the City of St. Petersburg has adopted an ordinance that provides for use of the UCM to collect the cost of abating nuisances resulting primarily from statutory criminal violations — such as prostitution, trespass, loitering, breach of the peace, and disorderly intoxication.13 The ordinance also allows for recovery of costs associated with violation of local codes governing noise pollution, dangerous dogs, and the sale of drugs.14

For these and similar ordinances, which seem to proliferate as local governments struggle to manage code enforcement issues and attendant budgetary concerns, several questions arise. First, do the proposed assessments fit the definition of “special assessments,” and meet the requisite special benefit and fair apportionment requirements? And, if they are special assessments, do they rise to the level of “non-ad valorem assessments” that can be levied using the UCM?

This article focuses on the provisions of chronic nuisance property ordinances that allow for the recoupment of nuisance abatement costs stemming solely from municipal code violations, which is possible under each ordinance referenced herein.15

Special Assessment or Service Charge?
There are unique benefits and limitations associated with the levy of a special assessment as compared to a tax or a user fee, the other major revenue sources in a local government’s tool box. However, the distinction among the three is often ambiguous.16 This ambiguity is particularly evident when evaluating nuisance abatement costs to determine whether they can be collected as special assessments or whether they must be treated as service fees.

Unlike a special assessment, which is mandatory and generally charged against all property in a particular locality for benefits provided, a service fee (also called a service charge or a user fee) is voluntary, paid in exchange for a government service provided to an individual person.17 Service fees can never be collected on tax bills.18

There are several (nonexclusive) factors that courts have relied on to distinguish between a special assessment and a service fee. These include the name of the charge; the amount of the charge as compared to the value of the service or benefit; whether it is charged only to users of a service or all residents of a given area; whether the charge is recurring or one-time; whether it is charged to recover costs of improvements to a defined area or infrastructure or for routine service; whether the charge is for a traditional utility service; and whether the charge is voluntary.19 The most substantive of these factors — to whom the charge is assessed, and whether it is voluntary — seem to weigh in favor of the proposed charges being service fees.

Most — if not all — chronic nuisance property ordinances allocate the costs associated with abating a violation entirely to the violating property, even though neighboring properties likely receive a benefit when a nuisance is cleaned up. 20 Thus, they are assessed solely to the immediate “user” of the services, in the manner of service fees.

Further, the abatement cost recovery charges are voluntary, in that any property owner can avoid them by maintaining a property nuisance-free. Of course, in our common usage of the term, abatement assessments are not voluntary in the same way that paying an entry fee to a park is voluntary, because once the abatement costs are assessed, a property owner must pay them. However, the term “voluntary,” when applied to the choice to use a government service does not necessarily imply an affirmative election to use that service; it solely means that a party has the option (however impractical) not to utilize the service. For example, one court held that a compulsory bridge toll was “voluntary” for a property owner whose only access to home was over the bridge because she had the choice to live in a different location and, thus, avoid the toll.21 Similarly, an assessment for nuisance abatement can be avoided by preventing the creation or perpetuation of nuisances. An analogous “voluntary” fee is cited in City of Gainesville v. State, 863 So. 2d 138, 146 (Fla. 2003), which states that “[b]ecause a landowner can refuse the [c]ity’s stormwater utility service and prevent liability for stormwater utility fees by containing runoff, the fees are neither a tax nor a special assessment.” Under this interpretation of “voluntary,” chronic nuisance abatement costs are technically — if not subjectively — voluntary.

Under Gainesville, then, chronic nuisance abatement costs are arguably fees, not special assessments.

Special Benefit and Fair Apportionment
In addition to consideration of the Gainesville factors, special assessments must meet a two-prong test: 1) the services funded must provide a direct, special benefit to the assessed property that is different in type or degree from the benefits provided to the community as a whole; and 2) the assessment for the services must be fairly apportioned to all properties receiving the benefit.22

While nuisance abatement services indisputably provide a “special benefit” to the nuisance property serviced, a standard chronic nuisance property ordinance does not “fairly apportion” the costs of such abatement to all properties receiving a benefit.23 Allocation of abatement costs entirely to the violating property assumes that the benefits of abatement accrue solely to the nuisance property. However, adjacent properties, and even the entire neighborhood, likely benefit when an eyesore is cleaned up — if in no other way, than through improved property value or market perception.24 The proportionate benefit of improved “market perception” has been discussed in general terms in several cases related to special assessments, although actually quantifying the benefit to each property is undoubtedly a difficult proposition.25

The ordinances discussed here do not attempt to allocate any portion of the proposed special assessments to neighboring property owners. Holding a violating property owner solely responsible for the burden on government services created by nuisance conditions on his or her property is understandable from both practical and equitable standpoints. But, is that enough to make it a fair apportionment for purposes of a special assessment?

In his according opinion in Florida Banker’s Assoc. v. FDFC, 2015 WL 5996764, No. SC14-1618 (Fla. Oct. 15, 2015), Florida Supreme Court Justice Lewis opines that “because special assessments are to be fairly and reasonably apportioned in accordance with the benefits received, it is implicit that more than one property will benefit from the improvement.”26 He adds that apportioning a special assessment to a single property is “completely inconsistent with the concept of apportionment and how special assessments have been traditionally applied.”27

The good news for local governments is that determination of a special benefit and fair apportionment is a decision for the legislative body establishing the assessment, and is given great deference, absent “arbitrariness.” 28

A decision is arbitrary if it is founded on preference, convenience, or prejudice, rather than on reason or evidence.29 Put another way, arbitrary decisions overlook unfavorable facts or logic to willfully reach a desired result or goal.30 In the proposed ordinances, the desire is to assess costs against the party creating the problem, which willfully ignores the benefits of abatement to other properties and, thus, could be held by a court to be arbitrary.31

Non-ad Valorem Assessments and the Uniform Collection Method
Assuming, with deference given to local government legislative findings, that the proposed nuisance abatement cost recovery charges are valid special assessments, is this the end of the inquiry? Not quite. There is one additional obstacle that must be overcome in order for special assessments to be collected using the UCM.

Special assessments can be placed on the tax roll only if they are also “non-ad valorem assessments.” Non-ad valorem assessments are defined as “only those assessments which are not based upon millage and which can become a lien against a homestead as permitted in [Fla. Const. art. X §4].”32 The only judgments that can become liens on a homestead property are liens “for the payment of taxes and assessments thereon, obligations contracted for the purchase, improvement or repair thereof, or obligations contracted for house, field or other labor performed on the realty.”33

“Taxes and assessments” include, among others, special assessments established by a city pursuant to the Municipal Home Rule Powers Act.34 Arguably, if a municipality could meet the burden of establishing code enforcement liens as special assessments, the liens would become part of the “taxes and assessments” contemplated in art. X. However, Florida Statutes expressly prohibit code enforcement costs and fines from becoming liens against homestead property.35 Further, in 2013, the Palm Bay v. Wells Fargo Bank, 114 So. 3d 924 (Fla. 2013), case held that a city or county cannot give super-priority to a code enforcement lien via ordinance.36

The Palm Bay case and F.S. Ch. 162 could, thus, lead to a constitutional challenge against the collection of nuisance abatement costs on tax bills. Should a non-ad valorem assessment for code enforcement costs be upheld as lawful, it could result in the indirect creation of a super-priority code enforcement lien, since taxes and assessments are a first lien on property.37 And if the assessment is placed on the tax bill and goes unpaid on a homestead property, the home could be sold at tax deed sale — the functional equivalent of a foreclosure on the lien.38 Thus, use of the UCM could potentially bypass protective laws relating to code enforcement, homestead property, and lien priority.39

County Property Appraisers and the UCM
The UCM is administered by the property appraiser and tax collector. Their roles are strictly ministerial, as long as the non-ad valorem assessments comply with the governing statutes.40 However, some property appraisers have already raised concerns that special assessments for nuisance abatement costs cannot comply with the requirements of the UCM, and have refused to list the assessments on the tax rolls. For example, in Volusia County, the property appraiser refused to include a proposed special assessment on the tax roll, concerned that “the punishment” of potentially losing a home at tax deed sale for a relatively minor code violation did not “fit the crime,” and arguing that the assessments were not uniform.41 The Okaloosa property appraiser has expressed similar apprehensions,42 and the Pinellas County property appraiser has declined to participate in the UCM for nuisance abatement costs, citing many of the concerns raised in this article.43

These conflicts suggest that some property appraisers and municipalities disagree on what constitutes “compliance” with the UCM statutes. On the one hand, a municipality can reasonably argue that it has complied with the statutes as long as all of the notice and technical provisions are met. On the other hand, a property appraiser might, equally reasonably, insist upon a more comprehensive compliance with the law, requiring that proposed assessments meet the definition of “non-ad valorem assessments.”44 After all, it seems inherent in the statutory scheme that the UCM cannot be complied with if the proposed charge is improper or unconstitutional. However, the degree of judgment that can be exercised by the property appraiser in administering the UCM is a question that has no clear answer,45 and should disagreements continue, judicial clarification may be necessary.

The Florida Supreme Court recently stated: “No system of appraising benefits or assessing costs has yet been devised that is not open to some criticism.”46 In advising clients considering adoption of chronic nuisance property ordinances, attorneys for cities and counties will need to carefully weigh the benefits against potential challenges — including constitutional challenges — that such ordinances could provoke.47

1 Jeff Patterson, Huge Fines Levied against Pinellas Homeowner with No Results, News Channel 8 WFLA (Tampa), Aug. 31, 2015,

2 Keyonna Summers, Dunedin Wants To Do More than Watch Foreclosures Go to Pot, Tampa Bay Times (St. Petersburg), Sept. 5, 2013, available at

3 After 17 Years Hillsborough Code Enforcement Gives Her 90 More Days, News Channel 8 WFLA (Tampa), Apr. 24, 2015,; 8 On Your Side Investigation Prompts Hillsborough Code Enforcement Change, News Channel 8 WFLA (Tampa), Sept. 16, 2014,

4 See, e.g., Tallahassee, Fla. Code §9-64 (defining “nuisance” property as any property on which there is an accumulation of “trash, debris, refuse, filth, or other noxious matter. . . [or overgrown] weeds, grass, or underbrush”).

5 See Annabella Barboza, Code Liens Are Not “Superpriority” Liens: Is It the End of the Debate?, 87 Fla. B. J. 28, 31 (Sept./Oct. 2013) (discussing the effect of abandoned foreclosure properties on neighborhoods and remedies local governments may have for rehabilitating those properties).

6 Fla. Const. art. X, §4. See, e.g., Flagler Live, Without Owner’s Consent, Code Enforcement Cleans up a Property at Taxpayers’ Expense (June 20, 2013), (stating that even when city resources are used to clean up an unsightly private property, liens for reimbursement of such costs go unpaid).

7 E.g. Cape Coral, Fla., Resolution 139-15 (Aug. 24, 2015) (establishing a non-ad valorem special assessment for lot mowing charges); Dunedin, Fla. Code §34-91 et seq. (2015); Fort Meade, Fla. Code §6-49 et seq.(2015); Holly Hill, Fla. Code §30-81 (2015); Lake Worth, Fla. Code §2-201 et seq. (2015); Madeira Beach, Fla. Code §34-403(a)(8) (2015); Redington Shores, Fla. Code §103-51 et seq. (2015); St. Petersburg, Fla. Code §9-61 et seq. (2015); West Palm Beach, Fla. Code §54-403 et seq. (2015). The City of Palatka tabled a proposed nuisance abatement cost recovery ordinance at public hearing, citing “possible legal issues” raised by attorneys representing the Florida Taxpayer Association and the Florida League of Cities. Palatka, Fla., Meeting Minutes (Nov. 14, 2013), available at

8 City of Gainesville v. State, 863 So. 2d 138, 144 (Fla. 2003); Donnelly v. Marion County, 851 So. 2d 256 (Fla. 5th DCA 2003); 1990 Fla. AGO 47 (1990).

9 City of Boca Raton v. State, 595 So. 2d 25 (Fla. 1992).

10 But see Harris v. Wilson, 693 So. 2d 945, 950 (Fla. 1997) (Wells, J., dissenting) (arguing that a tax does not constitute a special assessment merely because the assessment is “an efficient collection device”).

11 Lake Worth, Fla. Code §§2-221 (2015).

12 Fort Meade, Fla. Code §6-49 et seq. (2015).

13 St. Petersburg, Fla. Code §9-61 et seq.; see also Jennifer Titus, Crackdown on Nuisance Hotels in St. Pete, 10 News WTSP (Mar. 12, 2015), available at

14 Id.

15 See note 7. The level of nuance needed to evaluate each individual ordinance is beyond the scope of this article.

16 Gainesville, 863 So. 2d at 145; City of Clearwater v. Sch. Bd. of Pinellas County, 905 So. 2d 1051, 1057 (Fla. 2d DCA 2005); Okeechobee Util. Auth. v. Kampgrounds of Am., Inc., 882 So. 2d 445, 447 (Fla. 4th DCA 2004).

17 Gainesville, 863 So. 2d at 145.

18 Fla. Stat. §197.363(5); 1990 Fla. AGO 140 (1990).

19 Gainesville, 863 So. 2d at 145.

20 See, e.g., Dunedin, Fla. Code §34-85(b) (stating that “[c]hronic nuisance service costs shall be entirely apportioned to the assessed real property receiving the chronic nuisance service”).

21 City of Miami v. Haigley, 143 So. 3d 1025, 1031 (Fla. 3d DCA 2014), rev. den., 157 So. 3d 1043 (Fla. 2014).

22 Fla. Stat. §§170.01, 170.02; Collier Co. v. State, 733 So. 2d 1012, 1017 (Fla. 1999); Lake Co. v. Water Oak Mgt. Corp., 695 So. 2d 667, 669 (Fla. 1997).

23 See note 21.

24 “The attractiveness of the neighborhood strongly influences property values,” as do factors such as vacant properties, neighborhood crime, and nuisances including noise and odors. International Association of Assessing Officers, Property Assessment Valuation, 55-61 (2d ed., IAAO 1996).

25 See Donnelly, 851 So. 2d 256 (holding that enhanced law enforcement may render real property “more valuable and more marketable,” although that alone is not sufficient to constitute a special benefit); Quietwater Ent., Inc. v. Escambia Co., 890 So. 2d 525, 527 (Fla. 1st DCA 2005) (Hawkes, J., dissenting) (citing expert testimony that “enhanced law enforcement generally renders real property more valuable and marketable”).

26 (Internal citations omitted). This consolidated case relates to bond validation questions associated with the Property Assessed Clean Energy (PACE) loan program established in Fla. Stat. §163.08, under which government home-improvement loans are repaid as special assessments using the UCM.

27 Id.

28 Quietwater Ent., Inc., 890 So. 2d at 527; see also Citizens Advocating Responsible Envtl. Solutions, Inc. v. City of Marco Island, 959 So. 2d 203, 206 (Fla. 2007); Harris, 693 So. 2d at 947; Rosche v. City of Hollywood, 55 So. 2d 909 (Fla. 1952).

29 Black’s Law Dictionary 112 (8th ed. 2004); American Heritage Dictionary 124 (2d college ed. 1982); Bd. of Trustees of Internal Imp. Trust Fund v. Levy, 656 So. 2d 1359, 1362 (Fla. 1st DCA 1995); Agrico Chem. Co. v. State Dept. of Envtl. Reg., 365 So. 2d 759, 763 (Fla. 1st DCA 1978), cert. den., 376 So. 2d 74 (Fla.1979).

30 Id.

31 It may be worth noting that nuisance property owners — particularly in the case of criminal nuisances — may not be sympathetic characters. The general public may support allocating all abatement costs to the violators as “only fair”; however, that does not make the allocation appropriate under the law. The Florida Supreme Court has stated that “even an unpopular decision, when made correctly, must be upheld.” City of Winter Springs v. State, 776 So. 2d 255, 261 (Fla. 2001). It seems clear that the reverse must also be true — a popular decision, made incorrectly, cannot be upheld.

32 Fla. Stat. §197.3632(1)(d) (2015); see also Fla. Dept. of Revenue, Declaratory Statement, In Re: Petition of Samuel Cornwell, Tax Collector of Manatee County, Aug. 2, 1990, DLN: DS-079763, available at (declaring that a special assessment could not be included on the tax bill if it did not meet the strict definition of a non-ad valorem assessment).

33 Fla. Const. art. X, §4.

34 Fla. Stat. §166.021; Boca Raton, 595 So. 2d at 25; Morris v. City of Cape Coral, 163 So. 3d 1174, 1179 (Fla. 2015).

35 Fla. Stat. Ann. §162.09 (2015); see also Demura v. County of Volusia, 618 So. 2d 754, 756 (Fla. 5th DCA 1993) (holding that liens created pursuant to Fla. Stat. §162.09(3) — which includes code enforcement fines and costs — do not “exist[] as to such homestead property” while a property retains its homestead status) (emphasis in original); Mathieu v. City of Lauderdale Lakes, 961 So. 2d 363, 366 (Fla. 4th DCA 2007); Fong v. Town of Bay Harbor Islands, 864 So. 2d 76 (Fla. 3d DCA 2003); Miskin v. City of Ft. Lauderdale, 661 So. 2d 415, 416 (Fla. 4th DCA 1995).

36 Pelecanos v. City of Hallandale Beach, 914 So. 2d 1044, 1046 (Fla. 4th DCA 2005). Assuming that assessments for code enforcement costs can become valid special assessments — a question which, as discussed above, is not resolved — these restrictions create a paradox in which code enforcement liens would be “assessments” under the Constitution generally, but would be excluded from the basic definition of “non-ad valorem assessments” for the UCM under Florida Statutes and caselaw.

37 Allison Realty Co. v. Graves Inv. Co., 115 Fla. 48, 58 (1934).

38 Fla. Stat. §197.502, et seq.

39 Justice Lewis indicated his discomfort with this issue in his according opinion in the Reynolds v. FDFC case, calling it “troublesome” and stating that “to allow individual home repair loans to take precedent over preexisting mortgages would present significant constitutional concerns.” FDFC, 2015 WL 5996764 at *11. Sensitive to this issue, the Federal Housing Authority is attempting to address concerns about lien priority in the context of PACE, the subject of the FDFC case. See FHA, Guidance for Use of FHA Financing on Homes with Existing PACE Liens and Flexible Underwriting through Energy Department’s Home Energy Score (Aug. 24, 2015), available at (discussing forthcoming guidelines that will require the subordination of PACE financing to first lien mortgages).

40 Fla. Admin. Code R. 12D-18.001 (2015); Escambia Co. v. Bell (Bell), 717 So. 2d 85, 88 (Fla. 1st DCA 1998). However, mere technical compliance with the rules governing the UCM “cannot validate an improper non-ad valorem assessment levy.” Fla. Admin. Code R. 12D-18.003(5).

41 See, e.g., Chris Graham, Holly Hill Plans to Sue Property Appraiser to Strengthen Code Enforcement, Daytona Beach News-Journal, Feb. 26, 2014, available at While litigation was considered in this instance, it does not appear to have proceeded.

42 Tom McLaughlin, Okaloosa Still Working on Code Enforcement Policy, Northwest Fla. Daily News, June 11, 2015, available at (reporting that the Okaloosa County property appraiser refused to support a proposed ordinance placing chronic nuisance assessments on the tax bill because he “didn’t feel comfortable supporting a plan in which someone could conceivably ‘lose their home at a tax certificate sale because they didn’t clean their yard’”).

43 Letter from Pam Dubov, Pinellas County Property Appraiser & Diane Nelson, Pinellas County Tax Collector, to Pinellas County Municipalities, Re: Chronic Nuisance Ordinance (May 29, 2015) (copy on file with Pinellas County Property Appraiser’s Office) (“The very nature of the proposed assessments does not appear to be the type contemplated by Florida Statutes to be collected using the uniform method.”) The author represented the Pinellas County property appraiser in this matter.

44 Fla. Admin. Code R. 12D-18.003(5). Even with a strict focus on technical requirements, determining compliance is not simple. For example, the Bell decision directs that a county must comply with the procedural requirements of Fla. Stat. §197.3632 subsections (3) and (9), but neglects to address compliance with subsection (1), which defines which assessments can legally be collected using the uniform method. Bell, 717 So. 2d at 88. Compliance with uniform collection procedures by a taxing authority must include compliance with all governing statutory provisions, not just two subsections. See Gulfstream Park Racing Ass’n v. Tampa Bay Downs, Inc., 948 So. 2d 599, 606 (Fla. 2006) (“It is an elementary principle of statutory construction that significance and effect must be given to every word, phrase, sentence, and part of the statute if possible.”).

45 Despite the holding in the Bell case, “[t]he exercise of some authority, discretion, or judgment may be incident or necessary to the performance of. . . ministerial duties.” State v. A. Coast Line R. Co., 47 So. 969 (Fla. 1908). See also 2010 Fla. AGO 01 (2010) (“If a statute imposes a duty on a public officer to accomplish a stated governmental purpose, it also convers by implication every particular power necessary or proper for complete exercise of performance of that duty.”).

46 Morris, 163 So. 3d at 1180 (internal citations omitted).

47 For further research, see Harry M. Hipler, Limitations on Establishing Unsafe Structures Liens and Special Assessments: Homestead Exemption, Special Benefit to Land, and Public Purpose and Facility Doctrine, 85 Fla. B. J. 42, 43 (Feb. 2011) (see particularly, notes 18-26); Harry M. Hipler, Do Code Enforcement Violations “Run with the Land”? Competing Interests of Local Governments and Private Parties and Their Constitutional Considerations in Code Enforcement Proceedings, 43 Stetson L. Rev. 257, 265 (2014) (discussing code enforcement liens and homestead real property, and providing dozens of helpful citations); Susan Churuti, Chris Roe, Ellie Neiberger, Tyler Egbert, & Zach Lombardo, The Line Between Special Assessments and Ad Valorem Taxes: Morris v. City of Cape Coral, 45 Stetson L. Rev. ___ (forthcoming summer 2016) (discussing in-depth the establishment and apportionment of non-ad valorem assessments for fire services upheld in the Morris decision).

Amanda S. Coffey is an assistant county attorney at the Pinellas County Attorney’s Office and a member of the executive council of the City, County and Local Government Section of The Florida Bar. She received her B.A. with honors from the University of South Florida, and her J.D., cum laude, from Stetson University College of Law, where she served as an assistant editor for the Stetson Law Review. Special thanks go to Susan Churuti for her assistance with this article.

This article is submitted on behalf of the City, County and Local Government Section, Mark Moriarty, chair, and David Miller, editor.

City, County and Local Government