CORRECTIONS CORPORATION OF AMERICA v. CITY OF PEMBROKE PINES

Although municipalities typically do not have a duty to supply services to areas outside their boundaries, I recognize that a municipality may be required to supply services outside its boundaries if its conduct expressly manifested the desire or intent to assume such a duty. See Allen’s Creek Props., Inc. v. City of Clearwater, 679 So.2d 1172, 1174-76 (Fla. 1996). However, this exception, which is rooted in the concepts of detrimental reliance and estop-pel, does not apply here. CCA could not reasonably claim detrimental reliance because Pembroke Pines never expressly manifested its desire…