Walter E. Headley, Jr., Miami Lodge No. 20, Fraternal Order of Police, Petitioner v. City of Miami…

Summary

The Supreme Court of Florida approved the Fourth District Court’s decision and quashed the First District Court’s ruling, holding that under section 447.4095 an employer must demonstrate that no reasonable alternative funding source exists before it may unilaterally modify a collective bargaining agreement and that such modification may not occur until the impasse‑resolution process of section 447.403 is completed. The Court based its holdings on the plain meaning of the statutes and the strict‑scrutiny test articulated in Chiles, emphasizing constitutional protections for collective bargaining. Justice Polston filed a concurring opinion agreeing with the result but grounding the decision solely on the statutory language.