Department of Business Regulation v. National Manufactured Housing Federation, Inc.

370 So. 2d 1132 (1979)

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Department of Business Regulation v. National Manufactured Housing Federation, Inc.

Florida Supreme Court
370 So. 2d 1132 (1979)

  • Written by Tammy Boggs, JD

Facts

The state legislature passed an act to regulate rental-rate increases by mobile-home-park owners (the act). The act identified the problem of highly unequal bargaining power between mobile-home-park owners on the one hand and mobile-home-park tenants on the other. If an owner sought to raise rates, tenants would be significantly disadvantaged due to the high cost of relocating a mobile home. Under the act, the legislature created a state mobile-home tenant-landlord commission to regulate rental increases in mobile-home parks. The commission was part of an administrative agency. The act provided that if a park owner proposed a rate increase over a certain amount, tenants could petition for a hearing. At the hearing, the commission would determine whether an increase was “unconscionable or not justified under the facts and circumstances of the particular situation.” The act also provided that certain costs could be passed on to tenants, such as property taxes, if the costs were “reasonable and justified.” The act allowed the commission to adopt the owner’s proposed rate, maintain an existing rate, or set a different rate. A mobile-home-park owner (plaintiff) sued the relevant state agency (defendant), challenging the act’s constitutionality. The trial court declared the act invalid, and the state agency appealed.

Rule of Law

Issue

Holding and Reasoning (Boyd, J.)

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