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1992.10.14_PB_Minutes_Regulari lJ TOWN OF HIGHLAND BEACH PLANNING BOARD REGULAR MEETING - MINUTES Wednesday, October 14, 1992 9:30 A.M. Chairman Robert L. Lowe called the Regular Meeting to order in Commis- sion Chambers at 9:30 A.M. Deputy Town Clerk Doris Trinley called the roll. Present were the Chairman, Vice Chairman Arthur R. Keller and Members Paul R. Kane, Jr., Frank L. Colarullo and James F. Morrill. Members Leonard D. Bell and William Maltz were absent. Also present were Town Attorney Thomas E. Sliney, Building Official Lee Leffingwell and members of the general public. Upon MOTION by MR. KELLER/MR. COLARULLO, the Minutes of the September 9 Regular Meeting were unanimously approved. OLD BUSINESS None. NEW BUSINESS Amended Site Plan Review for Swimming Pool and Satellite Dish at 3510 S. Ocean Blvd., Lot 85W (St. Lucy's Rectory). Submitted by Brang Co. for the Diocese of Palm Beach (Owner). Building Official Leffingwell said she had reviewed the amended site plans and they did meet Code requirements; however she had requested additional engineering information on the satellite dish, which was received and attached to the plans. Jim Fideli, owner of Brang Co. and General Contractor for the project, next addressed the panel and answered questions to their satisfaction. Areas of discussion included: .Location of pool, which will be screened by a 6' shadowbox fence, plus ficus hedges on east, south and portion of west side. It was noted that although plans do not show a self-locking gate, one would be included. It was also noted the fence was an insurance requirement rather than a Town Code requirement. .The satellite dish would be placed on the south side of the rectory and screened from view by a mature ficus tree, which would be purchased specifically for this purpose. An existing palm might also be employed for screening purposes. It was also noted that the dish would be free-standing and the pole sunk into concrete. Planning Board • Regular Meeting - Minutes October 14, 1992 Page 2 of 4 .Regarding handicap access, it was explained that there would be no steps leading to the front of the rectory to be used by the public, rather access would be ramped. .There was no objection from the members to the request that the issuance of a Certificate of Occupancy not be contingent on the addition of the pool and satellite dish. Concluding discussion, MR. COLARULLO/MR. KANE made the following MOTION which met with unanimous favorable vote. THE PLANNING BOARD APPROVES AMENDED SITE PLAN FOR SWIMMING POOL AND SATELLITE DISH AT 3510 S. OCEAN BLVD., LOT 85W (ST. LUCY'S RECTORY). SUBMITTED BY BRANG CO. FOR THE DIOCESE OF PALM BEACH (OWNER); W.T. PATTERSON, P.E., JOB TS-103, DATED 7/13/92, SHEET 1 OF 1; DANIEL H. CARTER, LANDSCAPE ARCHITECT, JOB 91-298 REV. 9/24/92 SHEET SY-3; E.N. TURANO, ARCHITECT, SHEET SY-2R REVISED 9/24/92. Preliminary Review for Single Family Residence at 2445 S. Ocean Blvd., Lot 129E (North). Submitted by H. Frank LaHage, Owner, Highland Beach 10 Associates, Inc. John Conway, architect for the project, told the members this residence would be two-story, approximately 9,000 sq. ft. and include a 4-car garage and cabana. Because a set of plans had been previously approved for Lot 129E (North) at a Special Meeting on May 11, 1992, lengthy discussion en- sued among the members, owner H. Frank LaHage and Town Attorney Sliney. Mr. LaHage said the set of plans presented today were for a smaller house (previously approved plans were for approximately 11,000 sq.ft.), which was more in line with the size of the houses he had previously built in the area; he added that he would like to build the 11,000 sq.ft. house on lot 129E South. The members questioned if they could indeed review another set of plans for the same site; Attorney Sliney advised that Town records must be clear on as to what would be built on a specific site and in this case the record should show that the the first set of plans had been aban- doned. He also advised that Mr. Lahage would then have to re -submit the original set of plans to the necessary Boards for approval to built on 129E (South). is Planning Board Regular Meeting - Minutes October 14, 1992 Page 3 of 4 At this point in discussion MOTION was made by MR. KANE/MR. COLARULLO: THE PLANNING BOARD APPROVES PLANS FOR A SINGLE FAMILY RESIDENCE AT 2445 S. OCEAN BLVD., LOT 129E (NORTH), JOHN D. CONWAY, ARCHI- TECT, JOB 0992124 DATED 9/23/92, SHEETS 1 THROUGH 8. THE PLANS PREVIOUSLY SUBMITTED AND APPROVED ARE HEREBY ABANDONED BY THE PROPERTY OWNER AND APPROVAL OF SAME IS HEREBY REVOKED BY THE PLANNING BOARD. The members then convened to the table for further review before vote. During the ensuing discussion, attention focused on the concept that as long as the plans were "site specific," it would seem that any number of plans could be approved. And when a permit was finally pulled for whatever plans were ultimately decided on, then approval of all other plans would be negated. Subsequently, after consultation between the Building Official and the Town Attorney, it was ascertained that an applicant could have "x" number of approved plans for the same site in that when a permit was pulled for a specific set of plans, approval of the others would be automatically negated. Also, it was noted that if no permit was pulled within a year on any set of approved plans, approval would be null and void. It was, therefore, agreed that Mr. LaHage could have two approved sets of plans for the same site, or for that matter come before the Board for approval of any number of sets he desired, providing all plans pertained to a "site specific." However, Mr. LaHage's request that the first set of approved plans be assigned to the south portion of 129E, was denied. Attorney Sliney reiterated that he must re -submit plans to the necessary Boards, be they the first set of approved plans, or different ones; plans must always be "site specific," and in this case Mr. LaHage was asking that plans approved for Lot 129E (North) be automatically approved for 129E (South), which could not be done. Mr. Lahage accepted this conclusion and said he would possibly request a Special Meeting of the Planning Board to submit the first set of approved plans for Lot 129E (South). Accordingly, Mr. Kane/Mr. Colarullo withdrew their previous Motion. Following review and discussion, it was the consensus this could be a final review and, on advice of Attorney Sliney, the following MOTION was made by MR. COLARULLO/MR. KANE and met with unanimous favorable vote: THE PLANNING BOARD GIVES FINAL APPROVAL TO PLANS FOR A SINGLE FAMILY RESIDENCE AT 2445 S. OCEAN BLVD., LOT 129E (NORTH). SUBMITTED BY JOHN D. CONWAY, ARCHITECT, JOB 0992124 DATED 9/23/92, SHEETS 1 THROUGH 8. Planning Board Regular Meeting - Minutes October 14, 1992 Page 4 of 4 Chairman Lowe then invited Attorney Sliney to detail information con- tained in recent correspondence to Town Manager Mary Ann Mariano. Mr. Sliney advised that the case he cited in the correspondence, Jennings vs. Dade County, highlighted the need for Board members to avoid ex parte communications with petitioners. A copy of the correspondence is attached to and made part of these Minutes. It was noted the next Regular Meeting date fell on a Holiday (Veterans Day/November 11). It was the Consensus of the members that should there be an agenda, the Regular Meeting would be held Thursday, November 12. There being no further business to come before the Board, the meeting was adjourned upon MOTION by Mr. Morrill/Mr. Kane at 10:40 A.M. dmt APPROV ' Robert L. Lo , Chairman (�A e 0�61 Arthur R. Keller Vice C an Padl R. Kane, Jr. Flank L. COldrullo orr ATTEST: DATE: HODGSON, Russ, ANDREWS, WOODS & GOODYEAR j1 1800 ONE M S T PLAZA BUFFALO, NY 14203 (716) 856 -4000 MET FAX (716) 849-0349 GUARANTY FAX (716) 852-5185 10 19 THREE CITY SQUARE ALBANY, NY 12207 (518) 465-2333 FAX (518) 465-1567 THOMAS E. SLINEY PARTNER (A PARTNERSHIP INCLUDING PROFESSIONAL ASSOCIATIONS) ATTORNEYS AT LAW 2000 GLADES ROAD, SUITE 400 BOCA RATON, FLORID& 33431 BOCA RATON (407) 394-0500 PALM BEACH (407) 736-2177 BROWARD (305) 764-2440 FAX (305) 427-4303 September 10, 1992 Mary Ann Mariano, Town Manager 3614 South Ocean Blvd., Highland Beach, Florida 33487 Dear Mary Ann: RE: JENNINGS v DADE COUNTY iJ 1401 NEW YORK AVENUE, N.W. WASHINGTON, DC 20006 (202) 347-9898 FAX (202) 737- 1529 3 ROBERT SPECK PARKWAY, SUITE 880 MISSISSAUGA, ONT. CANADA L4Z 205 (PRACTICE RESTRICTED TO V.S. LAW) (416) 566- 5061 FAX (416) 566-2049 I am enclosing a copy of a recent decision concerning ex parte communications from Petitioners to Governmental Agencies with Board Members. This case indicated that ex parte communications from a Petitioner to Board Member should be avoided particularly if the communications is in the nature of lobbying rather than presenting facts to the Board Member. I know in the past when questions of this nature have come up Board Members have been reluctant to talk one on one with Petitioners or their Representatives and this case would substantiate that feeling. I would appreciate it if you would disseminate a copy of this case, and a copy of my letter, to the Chairman of the various Boards in Town. TES/t Enclosure Very,t'ruly yours, ThZ%� L, as E. Sliney HUG-25-1992 14:17 FROM CITY OF 30CA RATON TO 913054274303 P.02 • CITY HALL • 201 WEST PALMETTO PARK ROAD • BOCA RATON. FLORIDA 33432.3795 • PHONE: (407) 393.7700 SUNCOM: (407) 922 7700 August S, 1992 CITY ATTORNEY MBMORAMUM NO. 92-78 TO: Mayor and City Council FROM: crank S . B4rtolory4V City Attorney SUBJECT: Ex ParLe Communications with CouncilmcmberFs This memo is to advise you regarding complying with the race nt court decision of Jennings vs. Dade County. This decision as issued by the Third District Court of Appeal late last ye r. Recently the Florida Supreme Court has declined to review the decision, therefore making the holding of the case applicablelin all the Districts; in the state of Florida. I j A copy 'of the case and a memorandum furnished to several of the City boards tv which the cast may apply is attached. ple me read the attached memorandum as it contains a fuller explanation of the case and suggestions to avoid the pitfalls. which May arise as a result of !Ls applications. While the language of the case is very broad. and all encompass- ing, it appears that land use decisions, particularly.conditiin- al use applications is the area in which the case will have the most application to City Council. I know that individkal members of the City Council axe ;requently contacted. by o- ponents or opponents of a specific conditional use. ch contacts fall within the activity which the Jennings case appears to proscribe. I suggest that the individual council - members consider following the suggestions contained. in the attached memorandum when such contacts are made. Appeals from the Community Appearance Board, and the Planning and Zoning Board, sign code variances and the disposition of formal id protests are instances to which this case may apply. 9 --+ AN EQUAL OPP0ATUN)TY EMPLOYER AUG-25-1992 14:18 FROM CITY OF BOCA RATON TO 913054274303 P.03 0 10 19 Mayor and City Council Page 2 August 5, 1992 While we have always taken the position that resolutions qr t- ang conditional use applications v:hich involve the approval � a ;site plan are legislative (not quasi-judicial) decisions, the trend of the case law that such decisions are not legislative but are quasi-judicial (thus, subject to the Jens case) is clear. It is important to note that, in order to get the relief the case appears to authorize, it is necessary for an aggri party to go to court, prove the communication and have a j enter an order requiring a new hearing; however, it'is pru to consider that virtually every quasi-judicial action of City Council may. have that potential, especially -in tod litigious climate. If you have any questions or comments, please feel free contact me. FSH:gk Enclosures Huv �5-Ly9� 14:is FROM C'IFY OF 30CA RNTON f0 913054274303 P.04 • I[J CITY HALL - 201 WEST PALMETTO PARK ROAO • DOCA RATOM r1_U1wA :12143Z•9 795 - PHION Q (407) 393.7700 SUNCONt (407) 922-7700 August 5, 1992 CITY ATTORNEY MEMORANDUM No. 92-80 TO: Code Enforcement Board Civil service Board zoning Board of Adjustment Builders' Board of Adjus ent FROx: Christine P. Tatum Assistant City Attor y SUBJECTS Ex pane Communications with Board Mombars This memo is to advise you of the recent Court decision of Jennings vs. Dade County. This decision was issued by the Third Dlatriut Court of Appeal late last year. Recently tho Florida Supreme Court has declined to review the decision. Each of you sezvea on Boards which perform quasi-judicial functions for the City of Roca Raton. A Board acts quaii- judicially when it adjudicates private rights of -particular persons ati:er a hearing, which complies with due process e- quirements and makes finding of facts and conclusions of law`on the disputed issues. The Jennings case involves "ex parte" communications. A co - unication is considered "ex parte" when it occurs Out of he presence of all parties who will make a specific decision or are entitled to be notified of the hearing at which the decistho +on will be made. The Court in the Jennie s_ case held that when a Board sitting in a quasi-judicial function receives an ex contact, a presumption arias that the contact taus decisionmaker receiving the communication to prejudge* the and, unless the presumption of prejudice is rebutte complaining party may be entitled to a new and complete h� The Jennings case leaves many questions unanswered, whir undoubtedly be the subject of litigation in the future. ' keep you apprised of any further developments in this are in the interim, offer the following suggestions for deali ex party communications on quasi-judicial matters: • -� AN EQUAL OPPORTUNITY EMPLOYER — r iuu ��-1 j`jc 14: 19 FROM C ` I-Y OF 30CA RA LON f O 913054274303 ` P.05 Code Enforcement Board August 5, 1992 . Civil Service Board Page 2 Zoning Board of Adjustment Builders; Board of Adjustment 1. Any written ex parte communication relating to mat rs Which will come before your Board should immediately be trans- mitted to the Clerk of the Board for inclusion in the offic al record of the case. 2. If it becomes apparent during a telephone call or oral communication that the conversation relates to a quasi-judicial matter which will come before your Board, please advise the person communicating with you that such a conversation pis inappropriate and could jeopardize the validity of the decisQon regarding the matter to come before your Board. You sha ld advise the person to submit the substance of the communicat on to the Board in writing. If the communication continues, of er Its conclusion, you should consider creating a written docum nt reflecting that the communication occurred and relating the substance of the communication. This document should be for- warded to the clerk of the appropriate board for inclusion in the official record of the proceeding which was the ._subject lof the communication. I have forwarded a copy of the opinion in the Jennings caselto the attorney who represents your Board, so that they will'be • prepared to answer any further inquiries you might have regaX ing this matter. I CPT:gk I 0 PUG-25—L99L4:20 FROM C'TY OF BOCA RATON TO 913054274303 P.06 If the party laud ME a reepon se to d could raise the:,' 'after final judgmi 1e legislature sous i 768.72 would bi, 'is P-e 101y tlt4 V idh ortzorari is ;i q l&a the trial court°a;or far proceedings consistent concum ises>trt with opinion."..'a:=.': 6hieomri on the autttorilp Won u 54VVfL Ste also, t d Inden cbo's Sa Zd M Ma: 4th DCA ere is no reasoii�,o supreme court was riot 4;'I68.72, E'lorida Statutes,. assume that the staid v in the law. : irz. petition is untimely fi4 f the protective veil; suction for rebe'a" ' 'readition of the 'd the time for seel& . ME ItEHFARING s identa' motion for' Upon consideradaoa-by. e adapt the panel 'dC& decision. In all other t motions for rehesiiu9 'We therefore quash: rdera and remand for. eat with the panel tiPiu;. t, and DOWNEY,•: WARNER, POLEN UUM, JJ , concur.: '3EM4MOS Y. DADE -COUNTY ca.min ssa lug oR-%wI018L 1TN) ... STONE, J., dissents with opinion, with -5rhich LL"'M, ELRSET and GU14T=% Milton a. JENNINGS, AP concur. $TONE, Judge, dissenting. DADS COUNTY and i ..,,1 dissent for the reasons oTressed itt my Schatzman, AppolN ., t to the initial panel decision in this Nos. 88-1324, 88 -131 Appe2l- tr • O �YfrYOMItRiTSiN Joseph BM, Petitioner, T. Julie SANDLER end Iris Sandler, Respondents. No. 9b-1684. District Court of Appeal of Florida, R AIrth Diatdci. Dee. 27, 199L Petition for writ of acrSormi to tho Cir- cuit Court for Broward County; Lxanvnee L. Korda, Judge. ILT. Maloney of Fatterson, Maloney dt Gardiner, Fort Lauderdale, for petitioner. Wayne Kaplan of Kaplan do Gaylord, P.A., Boca Raton, for respondents. PER CURIAX We grant the petition for certim-,sri and quash the trial courVs order of May 24, 1991. See Henn R Sandier, M9 Sold 1384 (iris. 4th DCA 1991) (on motion for rehearing en band). GLICI{MM, C.S., and LEM and GUNTHER, JJ., concur. e #mN."Manal ' FditOer Noce The original opt„ no„ 4 ♦vgasr 6, 1"I is widmkawn from booed volume publkw District Court of Appeal of Third District 1337 Aug. 8, 1991.' On Rehearing Granted Dec. ,199E Landowner petitioned for 't of cer, tiorad to challenge trial court er which dismissed landowners count gists dine process violation as result of ex cam- mnnication between adjacent owner's lobbyist and county couuaiesio before vote approving use variance f adjacent landowner, which .gave to lando4mw leave to amend complaint only aga* county, and winch denied motion to 446iss count alleging nuisance ' as result of permitted use. Tha TNxtrkt t'.anrt of Ane a, Nesbitt. J. held on rehearing that: (1) 4 adowmes timely ped dos activated eo a -law cer- tiorari Jurisdiction; (2) lobbyisift ex parts oommar$cation could Ticlate dine proeets despite landowner's actual and c6trucUTe knowledge of ex parte communi4stion; and (� Iandotmet's prima fade sae I ex parts contacts would give rise to pees ption of prejudice and shift burden to �t land- owner and county to rebut presuropr lion. I Quashed and ,remanded. i Ferguaa% J.,: med ton g opinion upon grant of rehearing. e L Zonim and Plannici; QM7 I=downer's timely Iipt ' activated covunosrlaw certiorari jurisdighon to re- Tiew trial eourt' order whiclil dismissed count 41esting we parte co=q kation be- tween adjacent landownees JdAyist and county cornmissionera prior to , pmval of Lien beeause it it OV►rae&d 1y a0vk- en rehearing. . AUG-25-1992 14: 21 FROM f ' TY OF BOCA RAFON TO 9130542?4303 P. 07 ' 1338 Fla. 58' SOUTHFM REPORTER, 2d SERIES variance, which gave to landowner leave to amend complaint only against county and to transfer matter to appellate division of circuit wort, and which denied motion to dismica count alleging that use permitted by variance constituted nuiaaace; order was dopartarc from essential iequkau3ents of law and required plaintiff landowner to litigate putative claim In proceeding that could not afford relief ragllestad. E. Zoning -,And Planning p741 No i`aiyediment elisted to exercise of jurlsdiction over defendant landown,6, in that common-law certiorari jurisdiction was activntcd by plaintiff landowner's timely petition. a. Coaetltutionel Law 0 318(1) Quality of due process required in qua- si judielal hearing is not same as that to which party to full judicial hearing is enti- tled. West's F.B.A. Cont. Art. 1, § 9; U.S.C.A.. Const.Amends. 5, 14. 4. Adrninlstrntlre Law and Procedure 4-311, 913 Quasi-judicial proceedings are not core. trolled by strict rules of evidence and pro. cedure. 5. ConatitutlonaI Law e=318CI) . Quasi judicial dacinion based upon record la not conclusive if minimal stan- dards of due process are denied, West's F.S.A. Cant Art. 1. § 9; 11-S-r—A. Coast. Amends. 51 14. d. COMUtutlosral Law tw" 418CI) Quasi-judicial hearing generally meets, basic due process requirementsif parties are provided notloa of hearing and opportu. pity to be heard. West's F.S.A. Consl. Art. 1, § 9i U.S-CA. C=LAmends. 5, 14. 7- Zoning and Planning q.-.359 In quasi-judicial zoning proceedings, pa►•t;ee must be able W present evidence, eross•cxazaine witnesses, and be informed of ail facts upon which commission acts. 9. Constitutional Law 9=278.2(2) Ex parts oommuaicetjon between Iaad. owner's lobb7lst and county comrrtigriono..: before tbey mooted to approve use variance. for landowner could violate due process: despite ad*vint ndowner's actual or corn - Stru ti wlc of communication and FSas .A. Cot Arsubpoena, 9; lobbyist Coast Amends. 5, 14. 9. Administrative Law and Procedure, 4=314 Ex parte communications are inheftat- ly improper and are anathema to quasi• judicial proceedings; quasi judicial officer should avoid an such contacts where the, %re identifiable. 10. Administrative I.aw sad Procedure . 0-J14 Occarreuce of ex parte communication in quasi judicial proceeding does not man. date autoundlo rerersaL 11. Administrative Law and Procedure '4--wai4 Allegation of prejudice resulting from ex parts eontacta wt'tb decision makers la . quasi-judicial proceednrg states don. cause of ac- : 12. Administrative Law and procedure 4=314 171ron aggrieved party'a proof that ex Parts contact occurred with decision mak• ers is quasi-judicial proceedng. Its effect is presumed to be }cGjudlc,;a1, unlcas dafen- dant proves contrary by competence evi- dence. West's F.S.A. § 9o.3o4. 13. Constitutional Law 'S.318(1) In determining oejudl&] effect of ex parte communication allegedly violating due process in quasi& al court should cons; ria; what was gravi aicatlon; whether cc enced agency's ultir party making imprc from agency's ultin contents of common to apposing parties; of agency's decisioi proceedings would West's P.S.A. Const Const.Amends. 5, 1- 14. Counties 4=58 Allegation of pi& rnaaication in quasi fore county eornmi: maintain original eq to establish its clai 15. Counties C-68 Once claim of p munication in quasi fore County commis_ fending party will absence of prejudic 16. Zoning and Pis lr+rrdowner's p parte contact be - owner's lobbyist an, before they voted t for adjacent landov presumption of pre 90 sos f 1 17. Zoning and PIr Laadowaven p Paw contacts be owner's lobbyist an, they voted to app jj adjacent landowner county and 4acer Presumption of pre $ 90.304. I& Zoning and Plt To rebut pres from ex parts cc 'Judie Darkdull Rani N1JG-25-1992 14:22 FROM Ciry OF BOCA RATON TO 913054274303 P.08 JEMING3 Y. DADE COUNW Fla. 1339 eta, and bpi Informed ich commission acts. *to Y =9 li* ad 1337 due process in quasi: -judicial proceeding, tri- (1R. Ar►.3 tl & t"11 owners lobbyist and county comruia3looers , al court should consider the following trite• before they voted to approve. use variance ria: what was gravity of ex parts commu- for landowner, landowner could rely on any nication; whether contacts may have influ- favorable evidence presented during adja- ication between land- enced agency's ultimate decision; whether cent landowners case -in -chief. including aunty commissioners party making improper contacts benefited that adduced during cross-examination of approve use virianeo from agency's ultimate decision; whether adjacent landowner's witnattes. West's violate due proem contents of communications wore unknown F.S.A. 120.304. wrier's actual or con- to opposing parties; and whether vacating , t' communication and of agency's decision on remand for new e lobbyist, West's proceedings would serve useful purpose. 1 9;, U.S.C.A. Cont. West's F.S.A. Coast. Art. 1, 1 9: U.S.C.A. Conat.Amends. 5, 14. John G. Fletcher, South Miami, for appe! lant. aw and Procedure Mentions are inherent anathema to quasi• quasi-judicial officer contacts where they 0 and Procedure parte communication *ding does not man. ;al. .aw and Procedure judice resulting from ;h decision makers in :ng 31aitc3 cause of ac- Law and Procedure party's proof that ex Id with decision mak- roceeding, its effect is udiciaal, unions defen. i by competence evi. . § 90.304. .aw G=3180) mejudicial effect of ex n Allegrully violating 34. Counties 4=58 Allegation of prejudicial ex parts com- munication in quasi-judicial proccelOng be - fare county wrnmittion enables party W maintain orl&inal equitable cause of action to establish its claim. U. Counties a-0 Once claim of prejudicial ex parts com- munication in quasi-judicial proceeding be- fore county commission is established, of- fending party will be required to prove absence of prejudice. 16. Zoning and Planning 4-678 Landowner's prima facie case of ex parte contact bctwoen adjacent land, owner's lobbyist and county commissioners before they voted to approve use variance for adjacent landowner would give rise to presumption of prejudice. West's F.S.A. 1 90.304. Robert D. Kerner and Roland C. Robinr son, Miami, Robert A. Ginsburg. Count Atty.. and Eileen Ball Mehta and Craig Coller. Asst. County Attys.. for appellees Joel Y. Lumer. Miami, for The Sier Club as ArokU3 Curiae. Before BaKKDULL,• NESIIITr end FERCUSON, JJ. { 17. Zoning and Planning 4=679 • Landowners prima facie rave of ox parte contacts between adluimnt land - owner's lobbyist and commissioners before they voted to approve use variance for adjacent landowner would shift burn to county and adjacent landowner to rebut presumption of prejudice. West's Pak 4 90.304. 18. Zoning and Planning en679 To rebut presumption of prejudice from ex parts contacts between land- ' Judge llarkdull participated In dechlon only. ON REHEARING GRANTED NESB1717. Judge. The insue we confront is the effect of in cx partc communication upon a decisiin emanating from a quasi judicial proccediAl; of the Dade County Commission. Vile h4d- that upon proof that a quasi-jud'tdal offieizr ronived an ex part: contact, a presumpti n arises, pursuant to section 90.304, Flo a SuttuUm (089), that the cdntact was p u- d'tvbel. The aggrieved party will be sill id to a new and complete he firing efon . e commission unless the defendant pm es that the: communication was not, in f t. prejudicial. For the reasons that folldw. we quash the order under review with ldi- rectiom. Respondent Schattman -applied fora ar. lance to permit him to operate a quick oil clia,ege buaineas on him property adjaeod to that of petitioner Jennings. The Zooing Appeals Board granted Schatzman's re- quest. The etaunty communion upheld! he 1340 E9a. 589 SOUTHERN SWO97ER, 2d SERIES boards decisioon. Sir days prior to the commission's action, a lobbyist Schatsman employed to assist him in connection with the proceedings registered his identity as required by section 2•111(s) of the Dade County Ordinances. Jennings did not at- tempt to determine the content of any cane munication between the lobbyist and the commission or otherwise challenge the Pro- priety of any eommunkation prior to or.at the hearing. Following the commission order, Jen, rings Ned an actim for declaratory and injunctive relief in circuit court wherein he alleged that Sebatamaa's lobbyist commu- nicated with some or a0 of the county commissioners prior to the vote, thus deny- ing Jennings due process both under • the United States and Florida constitutions as well as section (W) of the Citizens' Bill of +tights, Dade County Charter. Jennings requested the court to conduct a hearing to a establish the truth of the allegations of the complaint and upon a favorable deteruiiva- i tics then to issue an iz*medon prohibiting use of the property as allowed by the coun- ty. Based upon the identical allegations, Jennings she claimed in the second count f of his complaint that Schatxmads; use of ' the permittod variwaee constituted a nut- . lance which be requested the court m err j6hL The trial court dismissed Count I of the complaint, against both Dade County ` and Schatzman. The court gave Jennings leave only against Dade County to amend the complaint and to transfer the matter to the appellate division of the circuit court. The trial court denied Schabman's motion '-` to dismiss Count U and required him to file ' an answer. Jennings then timely filed this application for common kw cerdorari. 11. 21 We have inA3diciion based on the following analysis. The trial courts order dismissed Jennings' equitable claim of non- 's rpx-rd ex party c ammunkations while it simultaneously reserved Jurisdiction for Jennings to amend his complaint so as to seek common law certiorari review pursu- ant to Dade County v Marta, SA, 326 Sa2d 188 (na.1976). Under Moss, Jen- nings wouhd be entitled solely to a review of the record as it now exist& However, since the content of ax rt paof the wdsting would prohibit the contacts' impact on the minstim This order so radically altering Jennings that it is the of requiring him to lit fortup. Thus, Jenain tiv tes our common tioa because the ord viewed a) constitutes a essential requirement:+ quires hen to litigate i proceeding that ¢annoy fief requested and for d afford h)m an adequap tillo n Jdimma-. , 87 e Norris u Soutihem f 824 So.2d 108 Wla. 4 same reasoning does] Schatsman. Nonethell jurisdiction, there is n exercieing it over Se4 (3-7] At the outset trial courts dismissal quality of due procesei judicial hearing is not� which a • party to f>di entitled.. See Gvw v. 96 S.Ct. 729, 42 L.EdA v. Department of Aai {Iaia»1982). Quasi-jucii not controlled by stil and procedure. See Real Eviate Comm * DCA I979r W ocdha, Sold W (Fla. 1st the)ess, certain standA must be -adhered to in process. Sege Hadtry City of3 dwd V. fin* Sd DCA•i9621. Consq cial decision booed up conclusiye if •nninimal t trill are denied. Sq Slate*, 298 U.S. 468, 911-12, 80 L.Fd.1288i lent, his u Arizona; Ariz. 541, 592 P.2d 3 quasi judicial heasiag jj due process requiremi provided notice of the arta contacts is not ,cord, such rvv6w ertainment of the :ommission's dater. s the effect then of relief available to incdonal equiralent gate in a different ' timely petition ar r certiorari jurisdia sought to be re. departure from the of law, and b) rw putative claim in a afford him the re. J hat reason does not r remedy. Ste TWA o.2d 412 (Fla195; ill Tel. & T*L Co., t MA 1960). The f not apply against: se, because we have i impediment to our staraan as a part)+.4 of our review of the we note that the required in a Quasi• the same as that to judicial hearingL Is :opus, 419 U.S. amp! t 725 (1975); Hadley : nia., 411 Sm2d 184 ial proceedings are i :t roles of evidence i Astors u Florida; d74 So.2d to (Fla. 3d R W. Williams W7 , DCA 1968). None• r& of basic fairness - order to afford dues 412 So.2d at 184; a 139 S9.2d 518 (Fls. iaantly, x quasi jadi- )n the record is not tandards of due pro- hfoTaan V. United I8041, 66 S.Ct. 906, ;1936); Western Gil- . Corp. Comm 121 'S (CtApp.1979). A enerally meets basic ats if the parties are hearing and an or HUU �,—Lyy� 14: 24 F-WUM t ' l Y OF SUCH RATON TO 913054274303 P_ 10 Tpt Pane contacts is not rt±cord. such } 3vir�w "M me .49 �liie a° commission's deter 185 the effect then of she' relief availabhs'bo _"functional equivalent tigate in a diifeiiit timely petltfon ac. 4 law certforari jurisdia girder sought to be ire. We- dePa'tmm frot the ;pts of law, and b) re. lie a putative claim in a scot afford him the re- for that reason does not !site remedy See 7Un- R kad 413 (Fla.I96s); &It Tel & n4 Co,, a lld DCA I960). The Poet• not apply a92inst !-!lees, because we have t bo Impediment to our &httautan as a party. 'of our review of the •- ao note that the regWrod in a quad - at to jttdfefal hearitlg fs sci-fi--., ' 411 'So.2d I84 e;, proceedings die ales of evideswe e 'u M id4 4 So.2d 40 {Fla, 3d VIA t< w.rr{az,Z4 2W loss). Norte. L�of>asic "k Dider to afford 8ne ;! -411 S0.2d at 184; .. 1ls9 Sold 513 (Fla, �uT. a � record is not 1M110dards of due pro. ^ited , a 5 s.0n ILL906, �.�>< Western. Gil Comm "14 121 iCupp.;! ate}. A meets basic If the Ptfaa are and se- op - JENMGS v. DADE COUNTY Fj Class= 3D.2d 1337 partunity to be heard. In quasi-judicial 0"A AM3 Drat 1"1) quasi-judicial proceedings. Qm MAU prvicet dlugs. the pirt es must* be ofilcers• should avoid all sud able to present evidence, sues -examine wit,. where they are Ident raNe. Hq tresses, and be informed of 4 the facts recognize the reality that carol upon which the oom kvion acts. (;Drat me e1mbed offic4ala In which p ta Reef Nuraerieg Inc. v. Babcock Co. 410 may unavoidably be the reapita So.2d 648, 662 (Fla. 3d DCA 1982).1 licited ex parbe cominunicatiom The reported decisions considering the gwsi fadioia2 znatt— thcy ore i due process effect of an ex pane commuar The ocaarreace of such a comma cation upon a quasi-judicial decision are it gaasi-ludicial proceeding does, conflicting. Some oousts }old that an ex (ktP iuttomatie reversal. Nevertl party communication does not deny due hold that the allegation of prejn Process where the substance of the comma 'was ing from ex party contacts with, nicatien capable of discovery by the lion makers in a quasi-judicial comPlaining ply in time to rebut it on the states a cause of action. T record So% &p., Ricitarti'eott v6 per%* Manapment; PATCO. Upon tIi 402 U.S. M. 410, 91 S.Ct. 1420, 14311-n. ed parry's proof that an ex par 28 L.Ecl.2d 842 (1971); United Air Lira, occurred, its effect is presumed to Iran V. C.A.B., W9 F.2d 238 (D.C.Cfr.19 ft diciai unless the defendant prove darrogt v &rimer, 225 F.Supp. 827, CU trary by competent evidence. (D.D.C.1964). Other courts focus upon the See p merctUy C4ld%VUl a Lhvis nature of the ex pane communication and tfriemewt, 372 So.2d 438 (t't'1a.197. whether it was material to the point that it eunion of rebuttable presumpti prejudiced.the complaining party and thus jug the burden od prvofl. Becai resulted in a denial of procedural due pro- edge and evidence of the tmntac, cess.. Mg., Waste Mortagemeat tc Pohl`► are peculiarly in the stands of the! Lien Cvn6rat Bd, 175 Iil.tlppAI 10P3, 125 qum jttdklal olficer(s)► we r d a IILDec. 524, 630 N.E.2d 682 (Ct.App.19ft den appropriate. Ste 9'aclartfco appeal deafed, 125 I11.2d 675, 180 MDer- Sys w AmeHezUe, 479 So.2d 81 400, 537 N.i:.2d M9 (108fi , Profoaaianai DCA 19W, Alielale Ana»oe' Air Trnfjia Controdiem Org •(pAX()) x XrnWMaet, 40 F.2d 740 (6th 1ilederal Labor Belatiom Aft., s8S Fad SV, 664- U (D-C'.C.a' jM*, Erdmas tt jl3i In delermittitt the 8 prep Iagraha*4 28 A.D.2d 5► 280 N.Y.S.2d 8W, feet of an ex Pate communicatia 870 (Ct.App.1961). dourt sbould consider the followi [61 The county adopts the first po$Wm which we adopt from PATCO, 61 564_ ft. and argues that leanings was not denied due process because he either knew or (whhether, as a result of ink should buys known of an ex parts comzau p communicatSons, the age - slonmamg p was nica,don due to the mandatory registration required of lobbyists. The eoanty further tainted so as to make tul4i he onntpnzlt< that IPnnings faiieli 1a argil him- mint of the agency >zlthe ei au iiuiocvai party or to the P> self of section =416.of the Dade County Code to' subpoena the lobbyist to testify at set that the agency was ob% the hearing so as to detect and refute the tecL In making tbh deterni number of coe►siderationa z+na; content of any ex parts communicatim We disagree with the couaiy's position vast: vast: the gravity, of the ex par [9-121 1x parte communi=Uons are in. Whether the coat have influenced the agency's nJ herentlJ improper and are anathema W cision; whether the party m I. It was conceded at oral t dzat dlu �8+�n hearins Wore the commission in this arse was gtzasiitzdidai. 1341 contacts ever, we icy they of unso• o decide- ication in not man- Kless, wR ce result. the ded- ,, Waste ARTHew s contact be preju- the em J 90.304. M of Be - (for dis- c affect- ie lmowl- 's impact h a bur- 1 TWso ma. 9d vrP. tR 4cia1 ef- the trial critesia F.2d at r ex deci- ate judg- ter as to tic inter i to pro- cation, a be rele- contmu- :ta may mate de. Ling the ^emu—G�-177G 1";e5 r-KUM 1''Y U- dUCR RRTON TO 913054214303 P_11 1342 Fla. 689 SOUTHERN REPORTER, Zd SERIES improper contacts benefited from the agenuy'a ultimate dacnion; whether the f contents of the commtmirations were un. known to opposing parties, who thet+e- tore had no opportunity to respond: and whether vacation of the agWM:y's deem t sion and remand for new proceedings would oft-ve a useful parpose. Since the ? • principal concerns of the court are the . integrity of the process and the fairness t of the result, incohoulatl rules have little i place in a judicial de ciaion whether to radate a voidable agency proceeding. In- stead, say such decWon must of ineows. ty be an exercise of equitable man. Accord E did N HauWW, Iu4. a Pallutiorn Control Bd, 116 M App.8d 586, 71 I11.Dee. 587, 603, 451 N.E.2d 556, 571(CtApp.19831 Wd, 107 I11.2d $3, 89 M.Dec. 821. 481 1 • N.Wd 664 (1986). (14,15] Accordingly, we bold that the allegation of a prejudicial ex party comma- tu""t in a quasiyudidal proceeding 1W fore the Dade County Commission will en- able a party to mabWa an orkftal eq. uitable causo of action to aatablish ifs claim. Once established, the offending par- ty will be required to prove an absence of prajatdiao.: -131 In the present case, Jennings' complaint does not allege that any comma I= nicatian which did occur caused lum prW- = dice. Consequently, we direct that upon rmand Jennings shall be afforded an op-portunity to amend his complaint. Vpon such an amendment; Jennings shall be pro- ` Tided an evidentiary hearing to present his pcc prima fame case that ex parts contacts occurred. Upon such proof, prejudi w shall r be presumed. The burden will then shift to the respondents tv sebut the preamnption r that prejudice occurred to the claimant- ' 2. In suck a proo"ris, the prinewes and am - lass of equity use appscable. Jae Z2 f-Wur.2d Equity 2g 44. at seq. (1950). 3. Ira rclawtins the presumption of preitadice. re- ernndent may rely on any favorable evidence s presented during the dainmies caaeeain chicf in. eluding that adduced during rvWondeat's crown examination of claimant's wlmesses. 4. Vnder die ?AIM rasa adupwil, v+ae at eke primary concerns is whether the ea parts cou>• Should the rerspondenta p�''� idence to dispel the prea>i wM become the duty of d determine the claim in ligli deem in the case." For the foregoing read Lion for common law testis The order& of the clrj quashed i and nemsaded i BARKMi4 J, contra FERGUSON, Judge (duo I concur in the mult an ky to address two argume lees: (1) This court in Co, itm !na a Nabcoak Ca. 41 34 DCA 19M, r0ecteid s goriza county commission trict boundary changes while treating hearings of special exceptions or vari judicial"; and• . M the pe; state a cause of action b, that a Iobbyist discusses private meeting with mem ty Commission prior w 0 clear from Judge Nesbitt; court that neither artun Legislativv and Qi in supper C of its argt Court has previously re, categorize county Comm district boundary cmmg while treating hearings special vacaptions or vi judicial',- Dude Gtanty XU7Mrierr, JkM V. Babm So.2d 648 Ma. ad DCA ment is made for the P1 this ease withitl what tl ntuateatiao•had sufficient ston and, therefore, whelf agencys decision and net accding would be likely 3. Nothtttg in tins aedston ing in Iptrh Waftwt Leap tux Cowuy. 448 Sold 117 (countf commission actin pacity). ,ce enough ev. ption, then it trial judge to of all the evi. the applies- is court n am l directions. write separat'. to of the appel t1 Rol Nurser. i So.28 848 Ma. tesapts to sate. aesrings on diet- s "legislative," applications for ne" as "quasi - honer does not alleging simply the cane In a an of tale Coatr i hearing. It Is opinion for the Mt is accepted. m% that ' [tpnis ted attempts to Eon hearings on as 'legislative', applications for mces as 'q=6 Les Caml Ric/ Company, 410 1M. The argu- mose of bringing respondents de• pact upon the dled- the vacation of d= id for a new pro champ the result l affect our bold- d,aaioa v. Mon - la. M = 1984) a le0a9vs es. riUV 2�-1'�y2 14:26 FROM C `Y OF BOCA RATON ro 913054274303 P.12 JF.NMGS T. DAD$ COUNTY l k ate m ses said IJ37 QU AM 3 248L 19911 hsttrlbe as a legielative-function exception to oorditions by maldag a new ,,the rule against ex parte commmicatmns. applied thereafter to all or sc ,iWeed, there is language in the Coral Ralf' those subject to its power. -optnlon, particularly the dk'ta that "it Is the Steburkn Afsdical Cext4m 597 • ebaractxr of the admiuistsstiye hearing (quoting ! yentis 1. Attantte 3ksdirig to the action of the administrative ,'body that determines the labor as legiala- tivo or quasi-judicial, Coral ,gee/ at 668, 'which, when read out of context, lends support to Dade County's contentions. As �sn abatraat proposition, the statement is inaccarate. Whereas the character of an administra- ,tive hearing wall dr!tprmine whether the proceeding is quasi-judicial or executive, De ,Grwt v Shqffiald, 95 S%24 912, 915 (Fla. -ISM. it is the nature of the act performed .that determines its character as It &lxtive .or otherwise. ,S'uburkn Medfeal Center o Olathe Community Xosp, 226 Kan. : W. 828,:697 P.2d 564, 661(1979). Sets also ;:Walgretn Co. K Polk County, 524 80.2d 1119. 1120 (Fla- 2d DCA 198M ('The qml judicial nature of a proceeding is rim al- Iered by nler'e procedural flaws.17. A Judicial inquiry layesopAes, declares and ezzforces liabilities as U W stand an present facts and under laws supposed already to slot. That is its purpose and end. Leglaktion, on tilt other band, leaks to the future grad cbaitgea erdatitlg .L , Relyin; on Costal Rerj, the maje»ity dpiaioa .4 raters to "quasi Judlc lai zoning peoceeeanim' a eonkundlog phrase which has its =coeds in Rtaker Mah riab Carµ v, 1let4 Cettnry. SU = 8a2d 904, 906, n. 2 (FL. 3d DCA 19a7). There Dade County argued to this COW that the ao cording of prooedunt due proocss' p eoavexts a leg(siaiira vc@w1tg into a quadjadfi:W pro ecedlm Mug Coral Reif. Tba proposition runs 9f" at in entire body of admtrasttative law. If an ad is in easenoc (egisbttiva in dwar, Car, the fact of a notice and a hearing does neat transform it into a judicis3 act. if it wvnld be a 10&18tive act without notice and a heaastag, it is still a leaislstive act with notice and a hearing. Set P„ cants Y. Aslant% Coast Line Co« 221 U.S. 210. 29 Sr_L 67,33 L13d. 150 (t9o8): Reogevt v. F&r m—'Lear & 7}urt CA, 1A U.S. 362, 14 3.tt. 1047.38 LFA 1014 (18%). A variance is a modification of the zoning 6'11,i"aw which may be granted whc a such variance will not be coonary to the public inter. an and when, gyring -to conditions peculiar to the property and' not the melt of the actions of eh4 apylleant. a Jacual eatorcawc at of the wJi- nance wand nsult in unnecessary and undue Ca., 211 U.S. 210, 226, 29 S.CL LPA 150 (1908)).t It is settled that the am" amending of toning ordinances i; tine function —by case law, Schal- of drfiami Broth, 112 33,.2d 83a NwAado a Mttagrom 519 Som 8d DCA 1987) (en bane). nv. (p So-2d 694 (8'taAM), by ststut4 162MSI and 166.041, Florid (1989), and by ordinance, Dad Code # 85-W8. See alto Anders Zaning, J Lla (24 FdA976) (zt legislative act representing a judgment as to how land withl should be utilized sad where ti demarcation between the sevt should be drawn); 101 C.J.S. Zt Land Manning it 1 (1968) (mu, also fairly settled- in this stau granting of variances.= and st. Owns or perutits, are quasi -Judi W4rgran Ca is PQ& County, 1119, U20 (Fla. 2d DCA 19881 New Smyrna Beads u aart,,N 642 (1; & bth DCA) (Cowart, J., i hardtltip. 7 Flalur2d, Bcdil tln& . LdRd Conn%* it 140 (19-15). Tina normal Function of a variant toil a change In ' Widmg restrwtiq and density n,nitrAnne but not Use Ckl dEcasoffi". GWrV v. A Voles; 154 5a2d 729 (Pia. 3d Dd 3. An admire4madve, body Aenc cp A wban it atift4catft private rights of person after a hearing which comps psuees requiremerits, said makes facts and conch dom oaf law on t isstta. Reviewing courts tan'utino ciai acts by aott•defemmal judicia Sm My of Apopka v. Orange Carte, 457 (Fla. 4th DCA 1974). On review of lc9blative acts, the i a deferential inquiry, ia. is the axe attiotasry ataltnrhy "fairly debatsli wW Rancho ft mowwwrs Ass)t CotauX 502 Sold 931 (Ra. 41b DG nfoe( 311 So.2d 9" (F12.1937i. iuc� no taquimment. that a government] ins iu Ica Iesialauvo capactry, supr with 1310nga of fact and axtclud 1343 to be part of d at 661 rt Line ,69,58 tent and a lagisle- er v. City 829 (Pita. 1W ii29 sections Statutes County a, Lazo of tins{ is a the city lines of tl Zones Ong and Q. It is that the d excep- actions.0 24 So2d city of 14 8o2d and i is to per. s or hetight change in nd Jhemr 1963). paticuiar svdth due Lndix p,�roo qmi judi- standards 299 So.2d wrt makes dse of dis• L.Jowl,- , Brvward 0,re,da er, tbetre is fir, mi- tts acdons -is of law. HUG-25-1992 14:29 FROM r-TY OF BOCK RATON TO 913054274303 P.14 gums-judlew and leg rain land nee cases, R�/► in acw dl�C Q' iding only that leghhl t lication for rezp�p� e stied on a subsequent �e same rezoning, Unless E sbow Substantial and nu. i eiccumstancea. ?+rsfger 675 So.2d 218 (Fla, 8d ling oa Coral Reef: An t; carol Res/ as holding ),longer a distinction be. .'actions and quasi-judicial commission in land use . ,.-Qd the actual holding of i.:clgariy erroneoua. ,gam be respondents on Izcaik ey America v Jfonine LN . 1170 (Fla. 3d ,DCA 1. tnaplaced- In that. es e otty commissioners. when eiris4tive capscdties. have W state their views- on mxttem. laaak Walton Wdreu the issue of ei iota or prehearing pro. �i iwiasl Proceedings. here that the behind. ! of the 00mmivdoner3 r..the purpose of influeno. Q as appeal from a quasi• ;: violated the Cfbzens, t. the Dade County char, -due process provisions of a�- a. to'PornsaitY. or the use of M°a� of bills, PuW1c as pc11 n"olve sates to the pmmotem *wme stu of 1UShtN Dade dies in pe"inent Pam e et'br hearing to which ra y bycextiorirl a Vorty or his 11etled to pnaest his C s or ar documentary evidence to �ot acx, and to coudusuch *Ibp a a theft facft or bbbouuponnthe MOMS Y. STATE Fla, 13 *%Msn 8644 tsst VJ&ApP.Z0bt, 1"1) the United States and h99rida C.onstitu (1979). Adherence to procedura Clone. We agree, obviously, that the lobby- suit fairness Ilia essential act a ing actions were unlawful. Dade County legal validity of the administrat and Schatzman respond that Jennings is tion, but also to the ntainten eaaa entitled to no solid because he h" not e0niidence in the value and soli alleged and demanatrsted a resulting prqu- this important Ebert pa'o! diae. In the opinion on rehearing tl& court WP.2d at 662 (cftg 2 Arm Jur l now clearly rajauttq that arsnment, istmOV0 Law 0 351)L The cots Prejudice is to be presumed, without fur cotupaisions which led to the esti ther proof, from the mere fact that any of rules rep=Ung the disqualf� county Commissioner gsaatsd s privntc as-- judge apply with equal force to dience to a lobbyist< whose purpose was to banal exercising judicial or qua solicit the eommiasioner to vote a certain fnncdOrls. 1 Am,Jar.2d Admi way in all administrative proceeding for Lam I (34 at goo (1962)C GVdbr oJS reasons not'neetssan7y addressed $olely to Use V. Ptori'da Pula Swot C(M the merits of the pttition. and that the So-24 620 (M-19M) (standard to commissioner did vott accordingly, Start. gualifying keney hands same ing with the legal definition of lobbying, used in disqualifying judge). .$eq M. note • 4 supra, and applying eommon eta v. Friedman, 4W F`.Supg, SC4 knowledge as to how the practice works, 1-97') (rule as to diagF-Sup , 4 there ie a compelling reason for placing the is ion ranee for administrative agenci burden of proving no prejudice on the part,Y for courts Davis,Ad responsible for the ex parte mmunica- fin Law ¢ 1204, at 260 (citing IL vis, ). lion. Board of Commlrs of Adams G Although an ex pane communication Wash.2d 503, $311 P.2d 940 (19# whit a quasi judiaal tribunal makes its S =1 action voidable, rather than vold par as-, the pre31ImPU011 which is drawn f vim the fact of the improper conduct, is applied to promote a atmag social pt7 and is arta. eient evidence to convime the fa*ftnd.,, that the innocent party has been preju diced; the rebuttable prc3umption iaipoaea upon the party against whom -it operates the burden of proof concerning the nonex- istence of the preannvd feint: 6 90-80d, Pla-Stat. (MY Department of Agrieui- fure If Consumer Sena. V. Bonanxq 568 S0•2d 24, 81-42 (b is lgWy Black's I.aw Dictionary i849 (4th ed. 1968k Ex pane lobbying of an administrative body actutg guasi'•ittdiaally denies the par ties a fair, open, and impartial hearing.' Suburban Medical Canter tx Olathe COm- rraunify HOOP-, 226 Kan. 820, W P.2d $54 a PA7W Y.. Federal idbor Rahrdmx Aud—*y. 665 R?d W (D.C,Ciram), relied an by Judge Nesbitt, supports this view. Tbere the taut! was ==—don 337(dxt) of !tie AQtmnings- aieations Tbc Act ems, in (C)6 that a member of the body involved In the lee isiae,et pewees wteo sceeirw say ptaidbited co mtmication awl place the Coates of the w o snrtonsttsnmr T Robert L. MORRIS, STATE of Florida, App No. i;l-0z5g7, District Court of Appeal of Second District, Rehearing Deified Dec. 6, APpesJ pursuant to Ma.R.App, from the Circuit Court rq Pinev Richard A. Lace, Judge. cxnmunicatfoo on public mcord. P states that where the comma knowingly made by a party in viol subsemon, tac party may be reg4 Cauft why his la m. or interest to Ca snot eel, or otherwise a �t�affeeted of such vtotagom; 3 U.&C.A. 9 : (D). 5-1351 which in- 17 to the e regula- of public dnesa of as-." !d I Admin- of tri- :d in dta- standard goo Roy. EM,Tea, ,f judges s as it is Ritter v. unty, 96 ) (same). 9.140(g) County, man was in of this "to show account TOTAL P.14