Haire v. Fla. Dep't of Agric. & Consumer Servs.

Summary

The Supreme Court of Florida upheld the constitutionality of Florida's Citrus Canker Law, which authorized destruction of citrus trees within 1,900 feet of an infected tree. The court held that the law was a valid exercise of the state's police power and that the statutory compensation schedule established a floor rather than limiting owners to token compensation. The court also addressed due process and Fourth Amendment challenges arising from the citrus canker eradication program.

Holdings

1. Section 581.184, Florida Statutes (2003), is a valid exercise of the State's police power and does not violate substantive due process because destruction of exposed citrus trees within the 1,900-foot radius bears a reasonable relationship to the legitimate governmental objective of eradicating citrus canker.
2. The statutory compensation schedule establishes a compensation floor and does not limit the State's obligation to pay full and just compensation as determined by a court.
3. The Citrus Canker Law does not violate procedural due process by authorizing removal through an immediate final order without a pre-deprivation hearing.
4. A magistrate may issue multiple search warrants for multiple specifically described properties based on a single affidavit and application when the affidavit establishes probable cause as to each property.
5. Absent a statute or rule prescribing another method, a magistrate may validly execute a search warrant using an electronic signature.

Questions Presented

1. Whether the Citrus Canker Law's authorization to destroy healthy but exposed citrus trees within 1,900 feet of an infected tree violates substantive due process.
2. Whether the statutory compensation scheme provides sufficient compensation to permit review under the rational-basis standard rather than the heightened standard applicable to uncompensated destruction of property.
3. Whether immediate final orders authorizing tree removal without a pre-deprivation hearing violate procedural due process.
4. Whether a single affidavit may support search warrants for multiple specifically described properties.
5. Whether a magistrate may validly affix an electronic signature to a search warrant.

Disposition

approved