Florida Department of Revenue v. Howard

This case requires us to decide whether section 193.016, Florida Statutes, violates the uniform valuation requirement of article VII, section 4 of the Florida Constitution.1 Although the trial court found only a portion of the statute unconstitutional, we conclude that the entire statute is facially unconstitutional.2

Subject to exceptions not relevant in this case, article VII, section 4 requires the legislature to enact a property valuation methodology for purposes of ad valorem taxation, and it directs that this methodology must be uniformly applicable to all types of property. Interlachen…