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Agenda 10/28/2014 Item #10B10/28/2014 103. EXECUTIVE SUMMARY Recommendation that the Board of County Commissioners direct staff to prepare an extension to the bank services agreement with 5/3 Bank to allow the county to re- solicit the county's bank services contract under the Board of County Commissioners, and to recognize that the bank services contract with First Florida Integrity is void since it was procured illegally. 5/3 Bank notified the County Manager ahead of the 9/23/14 Board meeting that it agreed to a month -month extension which information was placed on the record by Commissioner Hiller at the 9/23/14 board meeting. Contrary to the County Attorney's statement, no extenuating circumstances existed to justify waiving the County's Purchasing ordinance and procurement irregularities committed by the Clerk of Courts in his solicitation of the banking services contract. Further, that the public record reflects that the Clerk of Courts allowed First Florida Integrity Bank to modify its solicitation response after all bank responses were a matter of public record and the candidate banks had been interviewed, so as to make First Florida Integrity Bank the lowest net cost bank, a fact known to and ignored by the County Attorney. No other bank was allowed to modify its' response. That additionally, First Florida Integrity Bank provided a non - conforming response in that it did not have a trust company, a requirement to custody the county's securities; and instead, First Florida Integrity Bank intended to custody the county securities with a broker - dealer; that no custody agreement with the third party custodial provider was submitted as required by the solicitation; that the County Attorney had not even considered this material deficiency in his review of the First Florida Integrity Bank contract presented by the Clerk and approved by the Board on 9/23/14. That all these facts were known by Commissioners Henning, Nance and Fiala before their vote in favor of First Florida Integrity Bank on 9/23/14 since the evidence was in the back up material provided by the Clerk, as attachments to his agenda items. For these and other reasons already noted on the public record, 513 Bank, Wells Fargo and Sun Trust, which competed against First Florida Integrity Bank, have been irreparably harmed by the sham procurement of banking services by the Board of County Commissioners and the Clerk of Courts. OBJECTIVE: That the Board of County Commissioners recognizes that the Clerk of Courts illegally selected First Florida Integrity as the county's bank services provider and that it redirect the County Manager re- solicit the contract to cure the harm caused. CONSIDERATIONS: At the 9/23/14 Board meeting, the County Attorney incorrectly advised the Board that it could proceed with the ratification of the Clerk's contract with First Florida Integrity Bank, waiving the County's Purchasing Ordinance and the irregularities committed by the Clerk of Courts in selecting First Florida Integrity Bank as the contract award winner. 5/3 Bank, on 9/22/14, in response to the County Manager's request for a month -month extension, stated they would be willing to go forward with such an extension as the sole provider until a new bank was selected pursuant to a new county solicitation. See Ochs letter and e -mails attached. The 5/3 Bank response was placed on the record ahead of the vote by Commissioner Hiller at the 9/23/14 board meeting. The County Attorney ignored this and other facts in evidence. Additionally, material irregularities in the solicitation by the Clerk were intentionally ignored by the three commissioners, Henning, Nance and Fiala, all evidenced in the back up Packet Page -301- 10/28/2014 10.B. material provided by the Clerk on the public record as part of the agenda for that and earlier board meetings. Among the more significant irregularities was the fact that Clerk allowed First Florida Integrity Bank to modify its' bid to provide a competitive cost advantage by eliminating the compensating balance requirement it had originally made a part of its' solicitation response, and further that the Clerk ignored that First Florida Integrity Bank's response was non- conforming in that it did not have a trust company to custody the county's securities. No third party custodial agreement was provided to the Clerk, nor to the Board. No financial information about the broker - dealer was provided. The contract with First Florida Integrity Bank makes no mention of the broker - dealer custodial arrangement. The County Attorney negligently overlooked these deficiencies in his legal review of the transaction, and instead overzealously and incorrectly sought to find any means to try to legally validate the vote of three commissioners so as to protect them from personal liability which would result if they voted against his opinion had it been that the contract and procurement were legally insufficient. As such, the contract with First Florida Integrity Bank is void, and the county must re- solicit through the Office of the County Manager. Since 5/3 Bank is willing to extend its current contract monthly until a new bank is selected, there will be no interruption of bank services to the county. FISCAL IMPACT: None LEGAL CONSIDERATIONS: The First Florida Integrity Bank services contract is void due to illegality evidenced by material facts on the public record. There will be no interruption of essential banking services to the county. By re- soliciting, the board cures the harm against all banks that competed against First Florida Integrity Bank for the county's banking services contract. The County Attorney correctly opined that he could not find legal sufficiency with the Clerk's procurement process at the 9/9/14 Board meeting, and, then incorrectly opined that exigent circumstances existed when in fact they did not exist, to justify waiving the Clerk's procurement irregularities and the county's own Purchasing Ordinance so as to permit the Board to ratify the Clerk's selection of First Florida Integrity Bank as the county's bank service provider. RECOMMENDATION: Recommendation that the Board of County Commissioners direct staff prepare an extension to the bank services agreement with 5/3 Bank to allow the county to re- solicit the county's bank services contract under the Board of County Commissioners, and to recognize that the bank services contract with First Florida Integrity is void since it was procured illegally. 5/3 Bank notified the County Manager ahead of the 9/23/14 Board meeting that it agreed to a month -month extension which information was placed on the record by Commissioner Hiller at the 9/23/14 board meeting. Contrary to the County Attorney's statement, no extenuating circumstances existed to justify waiving the County's Purchasing ordinance and procurement irregularities committed by the Clerk of Courts in his solicitation of the banking services contract. Further, that the public record reflect that the Clerk of Courts allowed First Florida Integrity Bank to modify its solicitation response after all bank responses were a matter of public record and the candidate banks had been interviewed, so as to make First Florida Integrity Bank the lowest net cost bank, a fact known to and ignored by the County Attorney. NO other bank was allowed to modify its response. That additionally, First Florida Integrity Bank provided a non - conforming response in that it did not have a trust company, a requirement Packet Page -302- 10/28/2014 10. B. to custody the county's securities; and instead, First Florida Integrity Bank intended to custody the county securities with a broker - dealer; that no custody agreement with the third party custodial provider was submitted as required by the solicitation; that the County Attorney had not even considered this material deficiency in his review of the First Florida Integrity Bank contract presented by the Clerk and approved by the Board on 9/23/14. That all these facts were known by Commissioners Henning, Nance and Fiala before their vote in favor of First Florida Integrity Bank on 9/23/14 since the evidence was in the back up material provided by the Clerk, as attachments to his agenda items. For these and other reasons already noted on the public record, 5/3 Bank, Wells Fargo and Sun Trust which competed against First Florida Integrity Bank have been irreparably harmed by the sham procurement of banking services by the Board of County Commissioners and the Clerk of Courts. PREPARED BY: Commissioner Georgia Hiller - District 2 See Clerk's 9/23/14 Banking Services Contract Agenda Item Back/Up Material - accepted into the record by the BCC on 9/23/14 Attached Emails - County Attorney e -mail communications, County Manager Letter to 5/3 Bank, 5/3 Bank Email Confirmation Packet Page -303- 10/28/2014 10. B. COLLIER COUNTY Board of County Commissioners Item Number: 10.10.B. Item Summary: Recommendation that the Board of County Commissioners direct staff to prepare an extension to the bank services agreement with 5/3 Bank to allow the county to re- solicit the county's bank services contract under the Board of County Commissioners, and to recognize that the bank services contract with First Florida Integrity is void since it was procured illegally. 5/3 Bank notified the County Manager ahead of the 9/23/14 Board meeting that it agreed to a month -month extension which information was placed on the record by Commissioner Hiller at the 9/23/14 board meeting. Contrary to the County Attorney's statement, no extenuating circumstances existed to justify waiving the County's Purchasing ordinance and procurement irregularities committed by the Clerk of Courts in his solicitation of the banking services contract. Further, that the public record reflects that the Clerk of Courts allowed First Florida Integrity Bank to modify its solicitation response after all bank responses were a matter of public record and the candidate banks had been interviewed, so as to make First Florida Integrity Bank the lowest net cost bank, a fact known to and ignored by the County Attorney. No other bank was allowed to modify its' response. That additionally, First Florida Integrity Bank provided a non - conforming response in that it did not have a trust company, a requirement to custody the county's securities; and instead, First Florida Integrity Bank intended to custody the county securities with a broker - dealer; that no custody agreement with the third party custodial provider was submitted as required by the solicitation; that the County Attorney had not even considered this material deficiency in his review of the First Florida Integrity Bank contract presented by the Clerk and approved by the Board on 9/23/14. That all these facts were known by Commissioners Henning, Nance and Fiala before their vote in favor of First Florida Integrity Bank on 9/23/14 since the evidence was in the back up material provided by the Clerk, as attachments to his agenda items. For these and other reasons already noted on the public record, 5/3 Bank, Wells Fargo and Sun Trust, which competed against First Florida Integrity Bank, have been irreparably harmed by the sham procurement of banking services by the Board of County Commissioners and the Clerk of Courts. (Commissioner Hiller) Meeting Date: 10/28/2014 Prepared By Packet Page -304- Approved By Name: OchsLeo 10/28/2014 10.B. Title: County Manager, County Managers Office Date: 10/20/2014 12:26:36 PM Packet Page -305- 10/28/2014 10.B. Office Of the County' Manager Leo E. Ochs, Jr. 3299 Tamierni Trail East, Sure 202 • Napin Florida 34112- 5746 • (239) 2524383 • FAX 252 4010 September 12, 2014 Mr. Jim Miitciiell Fifth Third Bank 13350 Metro Parkway Ft. Myers FL 33912 Dear Mr. Mitchell: Thank you for taking my call yesterday in reference to the County, s banking service IIeeds. As we discussed, the County Commission has directed-me to solicit a banking services agreement for Board funds. Addition4y, I have been asked to research options for provisions of banking and merchant services to the Board on a month to month basis until such time as our solicitation, evaluation and contract award process is finalized. Specifically. I would like to know if your institution would be interested in providing these services on a temporary basis under the same general terms and conditions under which you have rendered services to the Clerk to the Board. J _. T look forward to hearing from you at your earliest convenience. Sincarely, Leo E. Ochs, Jr. County Manager J Packet Page -306- i 10/28/2014 103 ren From: Ray, Jim [Jim.Ray053.comj Sent: Monday, October 13, 2014 3:29 PM To: HillerGeorgia Cc: Ayers, Derrick; Mitchell, James Commissioner Hiller Fifth Third is willing to enter into a month to month contract with th4 BOCC under similar conditions as the existing contract with the Clerk of Courts to allow y u time to conduct an RFP process. We will need written direction from the BOCC with regards o any conflicting direction we receive from the Clerk regarding the BOCC funds during the tite is such contract. This is the same information that Jim Mitchell and I gave to the County Manager after of his letter. James C. Ray Jr. Senior Vice President Commercial Banking Executive Fifth Third Bank, South Florida 200 East Las Olas Suite 1200 MD BMME2A Fort Lauderdale, FL 33301 iim.rayk153.com 954 514 -3014 954 858 -1985 fax This e-mail transmission contains information that is confidential and may be privileged. It is intended only for the addressee(s) named above. If you receive this e-mail in error please do not read, copy or disseminate it in any manner. If you are not the intended recipient, any disclosure, copying, distribution or use of the contents of this informati is prohibited. Please reply to the message immediately by informing the sender that the message was misdirected. After replying, please erase it from your computer system. Your assistance in correcting this error is appreciated. Packet Page -307- 10/28/2014 10.B HayesKaren From: HillerGeorgia Sent: Saturday, October 04, 2014 12:00 PM To: HayesKaren Subject: Fwd: Purchasing Ordinance - Bank Services Contract Motion Follow Up Flag: Follow up Flag Status: Flagged Please print out this chain of communications. Sent from my Wad Begin forwarded message: From: GEORGIA HILLER <geor�iq!)a ff�' n)3C._c T > Date: October 3, 2014 at 1:53:26 PM EDT To: KlatzkowJeff ue.rtK .ir.rKOw Ei�CC�ilieov�nFt> Cc: HillerGeorgia Subject: Re: Purchasing Ordinance - Bank Services Contract Motion Seriously? Henning said Leo said nothing to him. I stated what Leo told me. And you didn't think you should ask Leo whether 5 /3rd was willing to extend when I stated so during the board discussion. Don't you have a duty to verify when a material fad that would void the motion as presented comes to your attention? On Oct 3, 2014, at 1:46 PM, KlatzkowJeff wrote: Commissioner. My recollection is that there was no evidence as to whether or not Fifth -Third was willing to extend. There was only what you said Leo told you, and what Henning said Leo told him. If Leo had an extension agreement he should have taken it to the Board on Executive Summary. Jeffrey A. Klatzkow County Attorney (239) 252 -2614 From: GEORGIA HILLER Sent: Friday, October 03, 2014 1:42 PM To: 10atzkow3eff Packet Page -308- 10/28/2014 10.B. Cc: HIIIerGeorgia Subject: Re: Purchasing Ordinance - Bank Services Contract Motion Except that you needed to ensure there really were exigent circumstances to warrant the waivers before you signed off on the motion as legally sufficient. I made it clear that 5/3 was willing to extend w/ board direction /approval. Why did you ignore the evidence I introduced that clearly invalidated the basis for the motion? From: KlatzkowJeff Sent: Friday, October 03, 2014 1:35 PM To: GEORGIA HILLER; HillerGeorgia Subje= RE: Purchasing Ordinance - Bank Services Contract Motion Commissioner: You are asking the wrong person. If any response was warranted it should have come from Leo, not me. I would have had no idea what recent discussion Leo may had with Fifth - Third; I would have had no idea what discussions Leo may have had with the Chair, l would have had no idea what discussions Leo may have had with you. I certainly had no discussion with Fifth - Third, as I waa not the one tasked by the Board to do so. Jeffrey A. Klatzkow County Attorney (239) 252 -2614 Front: GEORGIA HILLER [ Sent: Friday, October 03, 2014 1:19 PM To: Klatzkow]eff; HillerGeorgia Subject: Re: Purchasing Ordinance - Bank Services Contract Motion But what you knew from the county manager about 5 /3rd was contrary to what Henning said. Why didn't you speak up? Then I raised it before the vote. Why didn't you say something at that point? On Oct 3, 2014, at 1:10 PM, KlatzkowJeff < > wrote: We have reviewed on on -line video. Commissioner Henning's statement was as follows: "OK, I'm going to speak on the motion. I'm going to support the motion because it would prevent any delay of payment not only to our employees, but to our vendor. I've asked the County Manager several times to get back to me on if the bank, 5/3, would extend the contract; he has not done that, so I'm assuming the answer is no. Any other contract between the Board and any other bank at this time in what I consider an emergency would take a waiver of our policy, our purchasing policy. This went out to bid and it was scrutinized by several people and you know we must get on and do the public's business. So, is there any other questions or comments on the motion ?" I have no idea what conversations the County Manager had with the Chair. Any correction to this statement, or explanation as to the discussions with Fifth - Third, should have come from the County Manager. Packet Page -309- 10/28/2014 10.B. All l know is that there was no Executive Summary requesting the Board send a letter to Fifth - Third, which absence spoke volumes to me. Jeffrey A. Klatzkow County Attorney (239) 252 -2614 From: GEORGIA HILLER [ Sent: Friday, October 03, 2014 12:14 PM To: Klatzkowleff; HillerGeorgla Subject: Re: Purchasing Ordinance - Bank Services Contract Motion So, why didn't you tell the board what you knew about 5 /3rd when Henning improperly stated that 5 /3rd would not provide an extension? On Oct 3, 2014, at 12:01 PM, Klatzkow)eff < > wrote: So, to clarify, you didn't know that 5/3rd agreed to go month to month with board approval. ' ;ly Please provide the list of irregularities that the board waived at your direction. Did you ever talk with Sen. Richter regarding this solicitation/contract? Jeffrey A. Klatzkow County Attorney (239) 252 -2614 From: GEORGIA HILLER [ Sent: Friday, October 03, 2014 11:52 AM To: Klatzkowleff, HillerGeorgia Subject: Re: Purchasing Ordinance - Bank Services Contract Motion Thank you Jeff. So, to clarify, you didn't know that 5 /3rd agreed to go month to month with board approval. Please provide the list of irregularities that the board waived at your direction. Did you ever talk with Sen. Richter regarding this solicitation /contract? On Oct 3, 2014, at 11:16 AM, KlatzkowJeff < > wrote: Commissioner. With respect to Item 13A of September 23`d's Board meeting, in which the Clerk "Recommended the Board of County Commissioners (Board) approve the attached newly proposed three -party agreement for Banking Services between the Clerk, the Board and First Integrity Bank and acknowledge any waivers of the Board's Purchasing Policy as the solicitation was made in 2 Packet Page -310- 10/28/2014 10. B. accordance with the Clerk's purchasing policy," my thought process was as follows: 1. The Florida Supreme Court in Frankenmuth determined that a governing body has the ability to ratify an unauthorized contract provided that (1) the Board initially has the power to enter into such an agreement; (2) that the ratification be conducted in the same manner as if the agreement had initially come to the Board; and (3) that the Board has full knowledge of the material facts related to the agreement. 2. The Purchasing Ordinance, which was derived from the County's long - standing Purchasing Policy, provides in relevant part as follows: Sec. 2 -195. - Competitive Bid Process. E. Waiver of Irregularities: The Board of County Commissioners shall have the authority to waive any and all irregularities in any and all formal bids within lawful guidelines. (Ord. No. 2013 -69, § 10) Sec. 2 -215. - Waiver of Ordinance. The Board of County Commissioners shall have the authority to waive any and all Purchasing Ordinance provisions within lawful guidelines and upon formal Board action. (Ord. No. 2013 -69, § 30) Lawful guidelines as forth in Florida Statutes include (by analogy): Florida Statute Sec. 255.20 Local bids and contracts for public construction works; specification of state- produced lumber. (c) The provisions of this subsection do not apply: 1. If the project is undertaken to replace, reconstruct, or repair an existing public building, structure, or other public construction works damaged or destroyed by a sudden unexpected turn of events such as an act of God, riot, fire, flood, accident, or other urgent circumstances, and such damage or destruction creates: a. An immediate danger to the public health or safety; b. Other loss to public or private property which requires emergency government action; or C. An internrotion of an essential governmental service Moreover, the Purchasing Ordinance grants the County Manager great discretion to enter into agreements if exigent circumstances or an emergency exists. Since the County Manager has only that power delegated to him by the Board, the Board also has like power to act. Sec. 2 -210. - Exigent Circumstances, Emergency and Board Absence Purchases. In case of an exigent circumstance, which is defined as any circumstance requiring immediate action or attention, a valid public emergency, or during the Board's extended recess session(s) (all efforts should be made to obtain Board approval prior to anticipated recesses) whereby a purchase is necessary, the County Manager shall authorize the Purchasing Director to secure by open market procedure as herein set forth, any commodities or services. The County Manager shall have the authority to take actions including, but not limited to the issuance of contracts, change orders, and/or supplemental agreements. Any action shall be reported at the first available meeting of the Board of County Commissioners. The County Manager under the same consultations noted above shall further be authorized to approve payment(s) to vendors at the time of or shortly after purchase should the circumstances warrant. These payments shall be reported at the first available meeting of the Board. (Ord No. 2013 -69, § 25) Packet Page -311- It is my opinion that a bank depository is an essential governmental service, and that facing the expiration of an existing depository agreement without a replacement depository bank in place constitutes an exigent circumstance. I had several discussions with the County Manager prior to this September 23'd meeting. I asked Leo several times whether he could secure an extension of the current agreement with Fifth - Third. At the time of the September 23rd meeting, my understanding was that the best Mr. Ochs could then do was to get the Board at the September 23'd meeting to sign a letter requesting Fifth -Third grant an extension, which Fifth -Third would consider with no assurance that they would positively act on it. There was no Executive Summary on the published September 23rd attends seeking such a letter nor was such a request made on the Change Sheet. When the Clerk initially came forward with an agreement between the Clerk and First Integrity, asking in essence that the Board ratify his agreement, I stated that I would not sign off for legality. In that agreement the Board was not a party, and there was no protection for the Board should it take the requested action. When the Clerk amended the agreement to include the Board as a party, the agreement then fell within the confines of both the Frankenmuth decision and the Board's Purchasing Ordinance. The alleged irregularities of the process were discussed in detail during two public meetings. The Board, with full knowledge of the irregularities, had the lawful ability to waive any and all requirements and irregularities under the Purchasing Ordinance. The Board's decision was fwther bolstered by the fact that there was no substitute depository bank in place (which constituted an exigent circumstance as well as the loss of an essential government service), nor was there any requested action on the Agenda that the Board send a letter request to Fifth Third seeking an extension, which requested action would have given the Board the opportunity to continue this item one meeting. With this background, I prepared a proposed motion that the Chair could use provided the public hearing be consistent with the above. The purpose of the motion was to capture the considerations set forth above, in order to give the Board maximum protection against any claim should the Clerk's request be approved by majority vote. With respect to your question regarding the meeting, at Commissioner Fiala's request Leo and I met with Crystal and Derek Johnsen on September 15th. The primary issue was what could be done to get an acceptable Bank depository agreement to the Board. The three party agreement, as modified with staffs' input, resulted from this meeting. Jeffrey A. Klatzkow County Attorney (239) 252 -2614 ­-Original Message-- - From: HillerGeorgia Sent: Friday, October 03, 2014 7:55 AM To: Klatzkowleff Cc: HayesKaren Subject: Purchasing Ordinance - Bank Services Contract Motion Jeff, Please email the specific section of the purchasing ordinance that you relied on for allowing the board to waive the purchasing ordinance by motion due to exigent circumstances. Packet Page -312- 10/28/2014 10.B. Did you verify that exigent circumstances existed? If so, how? Please provide the specific law that you relied on to allow the board to waive Procurement MM;alarities with respect to the bank services solicitation and contract. Please provide a memo detailing your conversation in the meeting with you, Leo and the CIerk's staff ahead of the last board meeting where you determined how to craft the motion you then advised Commissioner Henning to make. When and where was that meeting held? Who was in attendance? With thanks, Commissioner Georgia Hiller Sent from my iPad Under Florida Law, e-mail addresses are public records. Ifyou do not want your e-mail address released in response to a public records request, do not send electronic mail to this entity. Instead, contact this office by telephone or in writing. <Frankenmuth.doc> 5 Packet Page -313- 10/2 8/2 014 1 0. B. Fir -4 Florida � Al-i Inteorltv J* 30. 2014 Conks C:omay Ch pit of the Circuit Coast Ms. AHm Bea. Pmo mft Speofaliet 3315 Thmismi Till Beat, 8ta 102 Naples, FL 341 IM324 Dar Aliosy Fire Florida btevity Book. -g; - iawe dw appmozaky we bed this momf with your edeodon, tmm. As a fellow up to aar meetin8. Fast Florida hO rky BankwM not regaise tine US million belsaoe segaue� sat as odshally bmSoabed is Oro request for proposal, Ibaw abo abePoedthe Podd" Ps3►hum that on be used. 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BrockMaryJo From: KlatzkowJeff Sent Thursday, September 04, 2014 8.09 AM To: OchsLeo Cc: TeachScott Subject: FW: REQUEST FOR FORMAL OPINION, FLORIDA ATTORNEY GENERAL, CONTRACT/PURCHASING Attachments: PURCHASING AGO REQUEST APP FINAL 9.3.2014.doc Follow Up Flag: Follow up Flag Status: Flagged Leo: This just came in. Please have your staff review and forward any comments or concerns to me. Jeffrey A. Klatzkow County Attorney (239) 252 -2614 From: Anthony Pires [ Sent: Thursday, September 04, 2014 7:45 AM To: KlatzkowJeff Cc: Dwight E. Brock Subject: REQUEST FOR FORMAL OPINION, FLORIDA ATTORNEY GENERAL, CONTRACT /PURCHASING f t 0 1 Packet Page -316- 10/28/2014 10.B. September - - - -, 2014 Honorable Pam Bondi Attorney General of Florida Department of Legal Affairs The Capitol PLOL Tallahassee, Florida 32399 -1050 Re: Request for Formal Legal Opinion, Collier County, a Non - Charter County, Re: Section 125.74(1)(m) Fla. Stat.; Legality and validity of contracts entered into by the Collier County Administrator or his designee(s) and not approved by vote or action of the Collier County Board of County Commissioners; Ability of the Clerk of Courts to make payment without Collier County Commission determination of valid public purpose. Dear General Bondi: This is a joint request by Dwight E. Brock as Clerk of the Circuit Court of Collier County, Florida (the "Clerk ") and the Board of County Commissioners of Collier County, Florida (the "Board ") for a formal legal opinion. The Board authorized this request at its meeting of April 22, 2014 (see Transcript, Exhibit "A "). A formal legal opinion is requested regarding the issues outlined in the questions listed below. QUESTIONS: Question 1: May the Board of County Commissioners of Collier County, Florida (the "Board ") delegate its discretionary spending authority to the Collier County Administrator (the "Administrator ") or his designees (which designees include any and all County employees under the Administrator regardless of position or title, collectively "Designees ")? Question 2: May the Board delegate to the Administrator or his Designees the Board's decision making authority to enter into binding contracts or agreements? Packet Page -317- 10/28/2014 10.B. Question 3: May the Board of County Commissioners of Collier County, Florida create contract thresholds, i.e. contracts of a value of less than $50,000, and delegate to the Administrator or his Designees the Board's power to execute contracts of a value of less than $50,000, without Board approval or without a Board determination of public purpose? Question 4: Are any contracts or agreements, entered into by the Administrator or his Designees, without either Board approval, Board vote or a Board determination of the existence of a valid public purpose, valid contracts or agreements? Question 5: May the Clerk lawfully make payments to persons under contracts entered into by the Administrator or his Designees without a Board approval or vote and without a Board determination of the existence of a valid public purpose? BACKGROUND THE CLERK Dwight E. Brock is the duly elected Clerk of Courts of Collier County, Florida. Collier County is a non - charter county under Article VIII, Section 1(f), Florida Constitution. The Clerk is a county officer pursuant to Article VIII, Section 1(d), Florida Constitution, ex- officio clerk of the Board of County Commissioners, auditor, recorder and custodian of all county funds. The Clerk by law possesses certain pre -audit functions and powers that require the Clerk to refuse to make expenditures or authorize disbursement of public funds that are illegal, and if there is any question as to the legality of payment, the Clerk cannot make such payment. Pursuant to the provisions of Section 129.09, F.S. (2013), if the Clerk of Courts, acting as county auditor, signs any warrant to pay any illegal charge against the County or to pay any claim against the County not authorized by law, or County ordinance, the Clerk shall be personally liable for such amount, and if the Clerk signs the warrant willfully and knowingly, the Clerk is guilty of a second degree misdemeanor. Thus the Clerk is both civilly and criminally liable for any improper payment. 2 Packet Page -318- 10/28/2014 10.B. THE BOARD The Board is the governing body of Collier County. Collier County is a non - charter county. Section 125.01, F.S. outlines various powers and duties of the Board as the governing body of Collier County. In that light, section 125.01(3)(a), F.S. provides, as to the powers of the Board, that: "(3)(a) The enumeration of powers herein shall not be deemed exclusive or restrictive, but shall be deemed to incorporate all implied powers necessary or incident to carrying out such powers enumerated, including, specifically, authority to employ personnel, expend funds, enter into contractual obligations, and purchase or lease and sell or exchange real or personal property." THE ADMINISTRATOR Part III of Chapter 125, F.S. is the "County Administration Law of 1974" Section 125.74(1)' F.S. outlines the powers and duties of the Administrator and in pertinent part Section 125.74(1)(m) F.S provides: "125.74 County administrator; powers and duties. — (1) The administrator may be responsible for the administration of all departments responsible to the board of county commissioners and for the proper administration of all affairs under the jurisdiction of the board. To that end, the administrator may, by way of enumeration and not by way of limitation, have the following specific powers and duties to: (m) Negotiate leases, contracts, and other agreements, including consultant services, for the county, subject to approval of the board, and make recommendations concerning the nature and location of county improvements." As clearly stated in Section 125.74(2), F.S., none of the governmental power of the Board as the governing body is delegated to the Administrator: "(2) It is the intent of the Legislature to grant to the county administrator only those powers and duties which are administrative or ministerial in nature and not to delegate any governmental power imbued in the board of county commissioners as the governing body of the county pursuant to s. 1(e), Art. VIII of the State Constitution. To that end, the above specifically enumerated powers are to be construed as administrative in nature, and in any exercise of governmental power the administrator shall only be performing the duty of advising the board of county commissioners in its role as the policy- setting governing body of the county" Section 125.74, F.S. will be referred to as the "Administrator's Statute ". 3 Packet Page -319- 10/28/2014 10. B. Pointedly, there is no provision in Part III of Ch. 125, F.S. that grants the Administrator, in non- emergency situations, the Board's power or ability to enter into contractual obligations. Consistent with the language in Section 125.74(1)(m), F.S., the Board adopted its Ordinance No. 2013 -40, the "Collier County Administrator's Ordinance" (the "Administrator's Ordinance "). A copy of the Administrator's Ordinance is attached as Exhibit ".Collier County has hired an individual to serve as the Administrator. Consistent with the statutory limitations in the Administrator's Statute, the Administrator's Ordinance grants to the Administrator only those powers and duties which are administrative or ministerial in nature and does not delegate to the Administrator any governmental power imbued in the board of county commissioners as the governing body of the county pursuant to the Florida Constitution. See Section 3 of the Administrator's Ordinance: "To this end, the below specifically enumerated powers are to be construed as administrative in nature, and in any exercise of governmental power the County Administrator shall only be performing the duty of advising the Board of County Commissioners in its role as the policy- setting governing body of the county and carrying out its directives and policies." The Administrator has hired numerous individuals and placed them in various positions under the Administrator. Notwithstanding the Administrator's Statute and Administrator's Ordinance, the Administrator has "delegated" to numerous such individuals, his Designees, the ability to enter into contracts or agreements on behalf of the County. THE PURCHASING ORDINANCE In 2013 the Board, in the context of the County's purchase or procurement of goods or services, consistent with both the powers of the Board outlined in Section 125.01, F.S. and the limitations on the Administrator contained in both Section 125.74(1)(m), F.S. and the Administrator's Ordinance, adopted Ordinance No. 2013 -69 as a substantially revised "Purchasing Ordinance the "Purchasing Ordinance ". (See attached Exhibit" "). In pertinent part, the Purchasing Ordinance provides (in the noted Sections): A. the Purchasing Director has the authority to negotiate all purchases for all County agencies except as required by State, Federal or Local Law. (See Section 5, Purchasing Ordinance). B. in keeping with Ch. 125, F.S., the Purchasing Ordinance grants to the Purchasing Director only those powers and duties which are ministerial in nature and does not delegate any governmental power 4 Packet Page -320- 10/28/2014 10.B. imbued in the Board of County Commissioners as the governing body of the County pursuant to Fla. Const. Art. Vlll, § 1(e) and to this end, the specifically enumerated powers are to be construed as ministerial in nature, for the purpose of carrying out the Board's directives and policies. (See Section 5, Purchasing Ordinance). C. the Board shall, prior to payment, approve all expenditures with a finding that such expenditures serve a valid public purpose. (See Section 7, Purchasing Ordinance). D. all contracts for commodities and services shall be authorized by the Board of County Commissioners. (See Section 19.F, Purchasing Ordinance). E. the Purchasing Department may prepare and recommend a Purchasing Manual for adoption by the Board. (See Section 6.4, Purchasing Ordinance). THE PURCHASING MANUAL Notwithstanding the limitations contained in the Administrator's Statute, Administrator's Ordinance and the Purchasing Ordinance, the Administrator and Purchasing Department have prepared a Purchasing Manual that, contrary to Section 125.74(1)(m), F.S., purports to delegate, vest and grant to the Administrator, the Purchasing Director and Designees, the ability to: A. not only negotiate but to execute contracts on behalf of the Board; and, B. enter into binding contracts on behalf of the Board- all without any review, action or approval of the Board. A copy of the proposed Purchasing Manual is attached as Exhibit The proposed Purchasing Manual also provides that purchases less than $50,000 may be entered into by the Purchasing Director, as the designee of the Administrator, without any review or approval of the Board and without a Board determination of the existence of a valid public purpose. As an example: 8:5 Non - Standard Agreements For purchases under $50,000, and for vendors who require a signed non- standard agreement, memorandum of understanding, contract, etc. the Purchasing Staff will complete negotiations with the vendor and forward to the County Attorney for final review and approval. The Purchasing Director shall execute the agreement on behalf of the Board of County Commissioners, and report the purchase pursuant to Section Seven. Purchases in General. An approved non - standard agreement may be approved by the Purchasing Director as long as the cumulative annual expenses are less than $50,000. 5 Packet Page -321- 10/28/2014 10.B. ISSUE CONTRACTS AND AGREEMENTS EXECUTED BY THE ADMINISTRATOR OR THE DESIGNEES The Administrator and his Designees (several other County personnel in the Administrator's agency) have signed contracts and agreements on behalf of the County even though: 1. the contracts or agreements were neither reviewed by nor approved by the Board; and, 2. the Board did not make any determination that the subject of these contracts served a valid public purpose. Some examples of these contracts and agreements, signed by County personnel, are attached as Exhibit " " to this request. In addition to the issue as to the validity of such contracts per se, as raised in this request, outlined above, some of the contracts or agreements appear on their face to suffer additional legal infirmities. z In addition, on several occasions after the Board has reviewed and approved the specific terms and conditions of a contract, County staff modified substantive terms and provisions without obtaining Board approval of the amended substantive terms or provisions. Attached you will find a Memorandum of Law from counsel to the Clerk (Exhibit "_ ") and a Memorandum of Law from the Office of the County Attorney (Exhibit "_ "). As outlined in the attached Memorandum of Law from counsel to the Clerk, the Clerk's attorney is of the opinion that: 1. the Board of County Commissioners of Collier County, Florida may not delegate its discretionary spending authority to the Administrator or his Designees. 2. the Board of County Commissioners of Collier County, Florida may not delegate its discretionary decision - making authority to the Administrator or his Designees. 3. the Board of County Commissioners of Collier County, Florida may not establish contract thresholds for the Administrator or his Designees to execute contracts without Board approval or vote or a Board determination of the existence of a valid public purpose; i.e., the Administrator or his Designees do not and cannot possess the 2 By way of example: A. the "Interlocal Agreement" between the County and the City of Naples dated February 8, 2011, signed by the Administrator (Exhibit _ - -�; B. the "Agreement for Visa Commercial Credit Card', dated October 7, 2008 (Exhibit C. 6 Packet Page -322- 10/28/2014 103. authority or power to enter into any binding contracts, regardless as to whether the contract is of a value less than $50,000. 4. contracts entered into by the Administrator or his Designees without either Board approval or vote, i.e, a Board determination of the existence of a valid public purpose, are not valid contracts. 5. the Board does have the ability to ratify and approve a contract that was initially an unauthorized agreement, provided that the three -prong test outlined in Frankenmuth Mutual Insurance Company vs. Magaha, 769 So.2d 1012 (Fla. 2000) has been satisfied. 6. the Clerk may not lawfully make payments to persons under contracts entered into by the Administrator or his Designees without Board approval or vote and a Board determination of the existence of a valid public purpose. 7. the Clerk may not lawfully make payments to persons under contracts entered into by the Administrator or his Designees where the Board has not made the determination of the existence of a valid public purpose. 8. approval by the Board of a summary "disbursement list" pursuant to F. S. 136.06(1) does not validate agreements or contracts which have not been reviewed and approved by the Board. (See Ramsey v. City of Kissimmee, 139 Fla. 107, 190 So. 474 (Fla.1939), Frankenmuth Mutual Insurance Company vs. Magaha, 769 So.2d 1012 (Fla. 2000). We have attached a number of documents that we believe will assist you in your consideration of this request, including the above referenced Memorandums Of Law outlining the Clerk's counsel's legal opinion, legal positions of the County Attorney, copies of the applicable ordinances and current policies, various contracts and agreements, as well as various County Commission meeting Executive Summaries. Your expeditious review and consideration of this request, and issuance of a formal opinion would be greatly appreciated. Thank you in advance for your consideration. Should you have additional questions, or require additional information please contact me or Crystal K. Kinzel, Director of Finance and Accounting at 239 -252 -6299. Packet Page -323- 7 4� LexisNexis� FOCUS - 20 of 24 DOCUMENTS FRANKENMUTH MUTUAL INSURANCE COMPANY, etc., Appellant, vs. ERNIE LEE MAGAHA, etc., et al., Appellees. No. SC96384 SUPREME COURT OF FLORIDA 769 So. 2d 1012; 2000 Fla. LEXIS 1889; 25 Fla. L. Weekly S 697 September 21, 2000, Decided PRIOR HISTORY: [ * *1] Certified Question of Law from the United States Court of Appeals for the Eleventh Circuit - Case No. 98 -2962. COUNSEL: J. Lofton Westmoreland and William R. Mitchell of Moore, Hill, Westmoreland, Hook & Bolton, P.A. for Appellant. Paula G. Drummond, Pensacola, Florida, on behalf of Appellee Ernie Lee Magaha; and David G. Tucker, Ja- net Lander, and James M. Messer, Pensacola, Florida, on behalf of Appellee Escambia County, Florida, for Ap- pellees. Carole Sanzeri, Senior Assistant County Attorney, Pi- nellas County Attorney's Office, Clearwater, Florida, for the Florida Association of County Attorneys, Inc., Ami- cus Curiae. JUDGES: LEWIS, J., WELLS, C.J., and SHAW, HARDING, ANSTEAD, PARIENTE and QUINCE, JJ., concur. OPINION BY: LEWIS OPINION [*1014] LEWIS, J. We have for review two questions of Florida law certified by the United States Court of Appeals for the Eleventh Circuit as determinative of a cause pending before that court and for which there is no controlling precedent. Specifically, the Eleventh Circuit has certified the following questions to this Court: 10/28/2014 10.B. Page 1 (1) UNDER FLA. STAT. § 125.031, WHICH REQUIRES AP- PROVAL OF THE BOARD OF COUNTY COMMISSIONERS FOR CERTAIN LEASE - PURCHASE [ * *2] AGREEMENTS, CAN A COUNTY BE HELD TO HAVE APPROVED A CONTRACT ABSENT FORMAL RES- OLUTION AND BASED SOLELY ON ACTS AND OMISSIONS OF THE COUNTY COMMISSION? IF SO, WHAT STANDARD GUIDES THE CONSIDERATION OF WHETHER A COUNTY COMMISSION HAS "AP- PROVED" A CONTRACT OR AGREEMENT? (2) IF THE LEASE - PURCHASE AGREEMENT HAS BEEN APPROVED, DOES THE NON - SUBSTITUTION CLAUSE IN THE LEASE - PURCHASE AGREE- MENT THAT PROVIDES FOR A PENALTY UPON NON - APPROPRIATION AND EX- PLICITLY DISCLAIMS USE OF REV- ENUES FROM AD VALOREM TAXA- TION VIOLATE ARTICLE VII, § 12, OF THE FLORIDA CONSTITUTION? Frankenmuth Mutual Insurance Co. v. Magaha, slip op., No. 98 -2962, slip op. at 10 (11th Cir. Aug. 25, 1999). We have jurisdiction. See art. V, § 3(b)(6), Fla. Packet Page -324- 10/28/2014 10. B. Page 2 769 So. 2d 1012, *; 2000 Fla. LEXIS 1889, * *; 25 Fla. L. Weekly S 697 Corrt. As more fully explained below, we answer the Note 2: One payment first certified question in the affirmative and determine of $ 200,000, two pay - that a board of county commissioners may approve a ments of $ 120,000, three lease- purchase agreement under section 125.031, Florida payments of $ 134,964, Statutes (1999), even absent formal resolution, if such and a final payment of $ board is not required by local ordinance or charter to take 319,743. action by formal resolution, as is the status of the local charter here. Further, we outline a three -prong test to Note 3: One payment [ * *3] guide courts in determining whether an approval of $ 200,000, six payments without formal resolution has occurred. Finally, we also of $ 419,008 and a final answer the second certified question in the affirmative, payment of $ 827,860. as rephrased below, and determine that the nonsubstitution clause implicates article VII, section 12 of the Florida Constitution, notwithstanding the attempt- Flowers signed each of these agree - ed disclaimer. ments as " Escambia County Comptroller." Although he warranted in paragraph 20 of 1. FACTS AND PROCEDURAL HISTORY the master lease that he had obtained a On September 6, 1995, Frankenmuth Mutual In- resolution of the "governing body" of the surance Company (Frankenmuth) filed a two -count jurisdiction authorizing him to execute the complaint in the [* 10 15] United States District Court lease, in fact, Flowers neither requested for the Northern District of Florida, Pensacola Division, nor obtained the permission of the Es- against both Escambia County, Florida, and Ernie Lee cambia County Board of County Com- Magaha (Magaha), the Clerk of the Circuit Court for missioners ( "the Board" or "the County Escambia County. Frankenmuth sought declaratory Commission ") before signing the agree - relief in Count I of the complaint and injunctive relief in ment. Count It. All three parties moved for summary judgment The master lease contains a number after participating in discovery, and the federal district of provisions relevant [. * *5] to this dis- court set forth the following facts in considering the par- pute. Paragraph 21 includes a ties' motions: "non- appropriation clause," which pro- vides the lease will terminate in any given year if the "legislative body or funding authority" fails to appropriate funds to In May 1992 Escambia County make the lease payments. The same para- Comptroller Joe Flowers signed a master graph also contains a "non- substitution lease agreement with Unisys Leasing clause," providing that, in the event of Corporation ( "Unisys "), under schedule non - appropriation, Flowers agrees not to 01 of which, Flowers agreed to purchase or rent any substitute computer lease - purchase a Unisys Model A -] l equipment for the balance of the appro- mainframe computer. [ * *4] ' The priation period and the one following it. schedule called for seven annual pay- Finally, an addendum clarifies that noth - ments totaling $ 2,353,814.1 In July 1993, ing in the lease shall be construed to con - the parties signed a second schedule stitute a pledge of ad valorem taxes and agreeing to add a Unisys imaging system that, in the event of default, the Lessor has for eight annual payments totaling $ no right to compel the County Commis - 1,164,635.2 In May 1994, the parties sion to appropriate funds to make the signed a third schedule adding further lease payments. equipment and restructuring the finance arrangement for schedule 01. This third The agreement continued without in- schedule called for eight annual payments cident for several years after it was exe- totaling $ 3,541,408.3 cuted. Flowers used the equipment for a variety of municipal functions, including Note 1: Six payments of county payroll and central data processing $ 304,112 and one pay- services for the County Commission as ment of $ 529.142. well as the Road, Mass Transit and Solid Waste Departments. (Ken Gardner Depo. Packet Page -325- 769 So. 2d 1012, *; 2000 Fla. LEXIS 1889, * *; 25 Fla. L. Weekly S 697 23 -24). In 1992 Unisys sold and assigned the lease to Chicorp Financial Services, Inc. Chicorp, in turn, sold it to Franken- muth Mutual Insurance [ * *6] Company ( "Frankenmuth ") - -the [ *1016] current owner of the lease and the plaintiff in this case. Although the County Commission and Flowers both regarded the Comptrol- ler to be a fee officer 4 rather than a budget officer, the evidence shows Flow- ers submitted his budget to the County Commission each year setting forth the fees he anticipated collecting, the expens- es he anticipated incurring and any antic- ipated shortfall between the two. Each year Flowers requested [that] the County Commission appropriate funds to cover the shortfall, which for fiscal years ending 1992, 1993 and 1994, amounted to roughly half the Comptroller's total budg- et. In each of those years, Flowers listed, respectively, $ 301,563, $ 304,561 2 and $ 304,113 as a budget expense titled "Debt Service -- Computer." Each year, the Board appropriated Flowers' requested funds without question. ' Note 4: Under Florida law, "fee of- ficers" are ones "assigned specialized functions within county government and whose budgets are established inde- pendently of the local governing body, even though said budgets may be reported to the local governing body or may be composed of funds either generally or specifically [ * *7] available to a local governing authority involved." § 218.31(8), Fla. Stat. (1993). The County Commission had no di- rect knowledge of the Unisys computer equipment, however, until it began dis- cussing implementing its own computer network system in 1993. By letter dated August 3, 1993 Flowers wrote to the Board's chairperson explaining his office already had a central data processing sys- tem and that the Board should adjust its plans to integrate that system. At a June 28, 1994 meeting the County Commission voted to amend its technology plan to make use of the Comptroller's computer equipment. 10/28/2014 10.B. Page 3 In late 1994, Flowers became the subject of considerable controversy when Escambia County lost millions of dollars in bad derivative investments made by Flowers' office. The political uproar led to a grand jury investigation and, eventually, a four -count indictment charging Flowers with malfeasance. Count Four specifically charged Flowers with malfeasance for entering into the Unisys lease in violation of Florida law. Flowers pled no contest and resigned from office. Thereafter, on August 1, 1995, the Florida Legislature abolished the Office of Escambia County Comptroller [ * *8] by repealing the Special Act that had cre- ated it. See Ch. 95 -529, Laws of Fla. As a result, Escambia County's elected Clerk of the Circuit Court, Ernie Lee Magaha, became responsible for the constitutional duties formerly held by the Office of Comptroller. 5 In the aftermath of these events, Magaha and the County Commis- sion obtained and reviewed, for the first time, the Unisys master lease and sched- ules signed by Flowers. After investiga- tion and discussion, the County Commis- sion determined the Unisys equipment was too old, too big, too expensive and too ineffective to serve the County's needs. The County Commission therefore advised Frankenmuth it [ *1017] would not make the 1995 schedule 02 and schedule 03 payments of, respectively, $ 120,000 and $ 419,000. The Commission further advised Frankenmuth it consid- ered the lease void and unenforceable due to Flowers' failure to obtain approval be- fore signing it Note 5: In most Florida counties, the Clerk of the Circuit Court serves a dual function: he or she manag- es the circuit and county court system and serves as "ex officio clerk of the board of county commis- sioners, auditor, recorder and custodian of all county funds." [ * *9] See Fla, Const. art. VIII, § 1(d). The Florida Constitution also provides, however, that individual counties may choose to divide the Packet Page -326- 769 So. 2d 1012, *; 2000 Fla. LEXIS 1889, * *; 25 Fla. L. Weekly S 697 'Clerk's duties between two county officers, one man- aging the courts and the other serving as custodian of county funds. Fla. Const. art. V, § 16. In 1972, Escambia County chose to divide the duties between two elected offic- ers: a Clerk of the Circuit Court and a Comptroller. See Ch. 73455, Laws of Fla. When the Legislature abolished that Act, the du- ties of the Comptroller re- verted to the Clerk of Court. Consequently, in September 1995, Frankenmuth filed this suit asking the court to declare the lease agreement valid and enforceable and to enjoin the County Commission and the Clerk of Court (as constitutional successor to the Comptrol- ler) from breaching the agreement. While the case proceeded through discovery, the County Commission purchased, in April 1996, a replacement computer system. As a result, Frankenmuth now seeks declar- atory relief only. These motions for sum- mary judgment followed. Frankenmuth Mut. Ins. Co. v. Magaha, 1996 U.S. Dist. LEXIS 15930, 10 Fla. L. Weekly Fed, D 340, D 340 (N.D. Fla. Aug. 30, 1.996). 1 According to the master lease agreement, ti- tle to the computer equipment vested in Flowers, the lessee, with Unisys retaining a security inter- est in the equipment and the right to repossess the equipment. Also under the master lease agree- ment, Flowers generally accepted responsibility for all risks related to the equipment. An adden- dum executed by the parties in September 1992 abolished Unisys' security interest in the equip- ment and its right to repossess the equipment, in- stead substituting other available remedies in the event of default, including seeking compensatory damages from the lessee should the lessee refuse to (1) sell the equipment; or (2) voluntarily return 10/28/2014 10.B. Page 4 the equipment (with Iegal and beneficial title) to the lessor. [ * *10] 2 The actual amount listed in Flowers' letter to the Board of County Commissioners dated May 8, 1992, for "Debt Service - Computer" actually was $ 301,561, not $ 304,561. 3 Flowers' budget request for the fiscal year ending September 30, 1992, was made by letter dated June 6, 1991, almost one year before the agreement with Unisys was executed. Further, the amount listed in the 1991 budget request for "Debt Service - Computer" was $ 301,563, simi- lar to the annual payments called for under the Unisys lease agreement. Finally, Flowers' budget request for the fiscal year ending September 30, 1993, was made by letter dated May 8, 1992, also before the agreement with Unisys was executed. As noted in footnote 2, supra, the amount listed in the 1992 budget request for "Debt Service - Computer" was $ 301,561, similar to the annual payments called for under the yet- to -be- executed Unisys lease agreement. After considering the above - listed facts, the federal district court made several determinations. See 1996 U.S. Dist. LEXIS 15930, * 19 -24, 10 Fla. L. Weekly Fed. at D 34143. First, [* * ] 1 ] the court determined that even though the County Commission had not approved the lease - purchase agreement prior to its execution as re- quired by section 125.031, Florida Statutes (1993), the Commission had subsequently approved the agreement by (1) appropriating funds to pay for computer equip- ment; (2) voting to change its own technology plan to integrate the computer equipment; and (3) taking no ac- tion after learning that an elected official in Escambia County had entered into a lease- purchase agreement in possible violation of section 125.031. ' See Franken- muth, 1996 U.S. Dist. LEXIS 15930, *20, 10 Fla. L. Weekly Fed. at D 341. Second, the court determined that the agreement's nonsubstitution clause rendered illusory both the nonappropriation clause and the express dis- claimer regarding ad valorem taxation, thus causing the agreement to be void as violative of article VII, section 12 of the Florida Constitution. See Frankenmuth, 1996 U.S. Dist. LEXIS 15930, *20 -22, 10 Fla. L. Weekly Fed. at D 341 -42. Third, the court determined that the nonsubstitution clause was void as against public policy because the clause "effectively contracted [ * *12] away the taxpayers' right to a central data processing [ *1018] system for up to two years." See 1996 U.S. Dist. LEXIS 15930, *22, 10 Fla. L. Weekly Fed. at D 342. However, the court further determined that the nonsubstitution clause was properly severable from the remainder of the agreement. See id Finally, the court determined that Magaha had no contractual obligations to Franken- Packet Page -327- 769 So. 2d 1012, *; 2000 Fla. LEXIS 1889, * *; 25 Fla. L. Weekly S 697 Muth. See 1996 U.S. Dist. LEXIS 15930, *23 -24, 10 Fla. L. Weekly Fed. at D 343. In accordance with theses determinations, the district court declared: Escambia County's Board of County Commissioners ratified the lease and all schedules between Unisys and Joe Flowers, the Comptroller of Escambia County. As the County Commission has failed to appropriate funds to make the lease payments, Frankenmuth may exer- cise its rights under the non - appropriation clause in paragraph 21 [of the lease - purchase agreement]. Franken- muth may not enforce the non - substitution clause, however, because it is void for violation of Article VII, § 12 of the Florida Constitution and for viola- tion of public policy. Frankenmuth has no contractual rights against Ernie Lee Magaha, Escambia County's [ * *13] Clerk of the Circuit Court. 1996 U.S. Dist. LEXIS 15930, *23 -24, 10 Fla. L. Weekly Fed. at D 343. Frankenmuth appealed to the Eleventh Circuit, and Escambia County cross - appealed. See Frankenmuth, No. 98 -2962, slip op. at 2 4 To support this third finding, the federal dis- trict court stated: "The evidence shows the ac- counting firm of Saltmarsh, Cleveland & Gund advised the County Commission through a 1994 independent audit that an elected official of the county had entered into a long -term lease agree- ment in possible violation of section 125.031." Frankenmuth Mut. Ins. Co. v. Magaha, 1996 U.S. Dist. LEXIS 15930, 10 Fla. L. Weekly Fed. D 340, D 341 (N.D. Fla. Aug. 30, 1996). The record shows that the independent auditing report stated, "Elected officials of the County have en- tered into lease purchase arrangements to obtain need property and equipment ... [that] appear to fall within the category of transactions which must be approved by the governing body of the County." This language is almost identical to that contained in the same auditing firm's 1991 report, which also did not specify what officials had en- tered into lease- purchase agreements in possible violation of section 125.031. 10/28/2014 10. B. Page 5 [ * *14] Or. appeal, the Eleventh Circuit discussed the issues regarding the execution of the lease- purchase agreement and the validity of the nonsubstitution clause. See id. at 5 -9. After discussing these issues, that court certified for this Court's consideration the two questions of law set forth above. Id. at 10. We now address those questions in turn. II. ISSUES AND ANALYSIS A. THE FIRST CERTIFIED QUESTION In the first certified question, the Eleventh Circuit has asked us to determine whether, consistent with the requirements of section 125.031, Florida Statutes, a board of county commissioners may approve a lease - purchase agreement absent formal resolution, and, if so, what standards guide consideration of whether such an approval has occurred. As explained below, we de- termine that a board of county commissioners may ap- prove a lease - purchase agreement under section 125.031, even absent formal resolution, if a governing charter or ordinance does not require the board to take action by formal resolution, as is the situation here. i Further, we provide a three -prong [ * *15] test to guide the determi- nation process as to whether an approval without formal resolution has occurred. Before we reach the first certi- fied question, however, we must fast address Franken- muth's argument that Flowers, as the Comptroller of Escambia County, had the independent authority to enter into the agreement with Unisys even absent any approval whatsoever by the Escambia County Board of County Commissioners (the Board). If Frankenmuth's argu- ment on this point is correct, then we need not reach the first question certified by Eleventh Circuit. 5 The parties have not referred us to any provi- sion in the Escambia County Code requiring the Board to take action in some specified manner. After careful consideration, we find Frankenmuth's argument regarding Flowers' independent authority to bind the governmental entity to be without merit. It is clear that Flowers, as Comptroller of Escambia County, was a constitutional officer under the Florida Constitu- tion. See art. V, § 16, Fla. Const.; art. VIII, § [ * *16] 1(d), Fla. Const,; see also Alachua County v. Powers, 351 So. 2d 32, 35-43 (Fla. 1977). It does not follow, however, that Flowers had the independent authority to enter into the agreement at issue here. As we noted in Powers, the clerk of the circuit court-or the comptroller if duties are divided between two offices- derives author- ity and responsibility from both "constitutional and stat- utory provisions." Powers, 351 So. 2d at 35; see also Escambia County v. Flowers, [ *1019] 390 So. 2d 386, 387 (Fla. 1st DCA 1980) (stating that Flowers' duties as Packet Page -328- 769 So. 2d 1012, *; 2000 Fla. LEXIS 1889, ** 25 Fla. L. Weekly S 697 comptroller were enumerated by legislative prerogative); cf. State v. Walton County, 93 Fla. 796, 800, 112 So. 630, 632 (1927) (noting that "[T]he board of county commissioners of each county are constitutional officers, and under the terms of the Constitution their powers and duties shall be fixed and prescribed the Legislature. "); Weaver v. Heidtman, 245 So. 2d 295, 296 (Fla. 1st DCA 1971) (observing that counties are "subject to legislative prerogatives in [ * *17] the conduct of their affairs "). By enacting section 125.031, the Legislature clearly estab- lished that agreements such as the one at issue here may not be entered into without approval by a board of coun- ty commissioners. This is not an instance where the clerk of the circuit court is acting as an arm of the judi- cial branch and thus under judicial control and not the control of the Legislature. See Times Publishing Co. v. Ake, 660 So. 2d 255, 257 (Fla. 1995). Therefore, the Legislature's pronouncement in section 125.031 is con- trolling here, and Flowers did not have the independent authority to enter into the agreement with Unisys without the approval of the Board. b 6 It is interesting to note that Flowers entered a polo contendere plea to the charge of violating section 125.031, Florida Statutes; if Franken- muth's argument were correct, then Flowers' plea would have responded to a charge having abso- lutely no basis in law. Further, Frankenmuth's argument on this point is inconsistent with lan- guage contained in the underlying agreement, which stated in paragraph 20(b): "Lessee [Flow- ers] has been duly authorized by the Constitution and laws of the applicable jurisdiction and by resolution of its governing body (which resolu- tion, if requested by Lessor, is attached hereto), to execute and deliver this Lease and to carry out its obligations hereunder." If Frankenmuth's argu- ment regarding Flowers' authority were correct, the language in the agreement regarding a resolu- tion by the governing body of the jurisdiction would be superfluous and meaningless. [ * *18] Turning now to the first question certified by the Eleventh Circuit, we must consider the text of section 125.031, Florida Statutes (1999):' Counties may enter into leases or lease - purchase arrangements relating to properties needed for public purposes for periods not to exceed 30 years at a stipu- lated rental to be paid from current or other legally available funds and may make all other contracts or agreements necessary or convenient to carry out such 10/28/2014 10. B. objective. The county shall have the right to enter into such leases or lease - purchase arrangements with private individuals, other governmental agencies, or corpora- tions. When the term of such lease is for longer than 60 months, the rental shall be payable only from funds arising from sources other than ad valorem taxation. Such leases or lease- purchase arrange- ments shall be subject to approval by the board of county commissioners, and no such lease or lease - purchase contract shall be entered into without said approval. Page 6 It is undisputed in this case that Flowers failed to obtain the express or formal "approval" [ * *19] of the Es- cambia County Board of County Commissioners (the Board) before entering into the agreement with Unisys. Therefore, the initial question we must answer is whether the Board had the power to approve the agreement after it was executed. We determine that Florida law clearly establishes that the Board had the power to approve, or, stated another way, ratify, that which was initially an unauthorized agreement after it had been executed. See, e.g., Ramsey v. City of Kissimmee, 139 Fla. 107, 111 -13, 190 So. 474, 476 -77 (1939); Brown v. City of St. Peters- burg, 111 Fla. 718, 720, 153 So. 140, 140 (1933); cf. City of Panama City v. T & A Util. Contractors, 606 So. 2d 744, 747 (Fla. [ *1020] 1st DCA 1992) (holding that city ratified city manager's unauthorized termination of contract between city and third party); Tolar v. School Board of Liberty County, 398 So. 2d 427, 428 -29 (Fla. 1981) (finding that municipality's action taken in viola- tion of Sunshine Law could be later ratified if taken in accordance with such law); see generally l0A Eugene McQuillin, The Law of Municipal Corporations, § 29.104 at 63 [ * *20] (3d ed. 1999) ( "It is a general rule that whatever acts public officials may do or authorize to be done in the first instance may subsequently be adopt- ed or ratified by them with the same effect as though properly done under previous authority. "). The diaposi- tive question thus becomes, what constitutes "approval" by the Board within the meaning of section 125.031? 7 We quote the current version of the statute because the Legislature has not amended the stat- ute since 1989. See ch. 89 -103, § 1, at 279, Laws of Fla. Thus, the current version of the statute is the same as the version in effect at the time the events in the present case transpired. Section 125.031 does not define the term "approval" as used in the statute, nor does the legislative history underlying the statute shed any light on the matter. 8 Un- der such circumstances, we must give the statutory Ian- Packet Page -329- 769 So. 2d 1012, *; 2000 Fla. LEXIS 1889, * *; 25 Fla. L. Weekly S 697 guage its plain and ordinary meaning. See, e.g., [ * *21] Green v. State, 604 So. 2d 471, 473 (Fla. 1992) ( "One of the most fundamental tenets of statutory construction requires that we give statutory language its plain and ordinary meaning, unless words are defined in the statute or by the clear intent of the legislature. "). In ascertaining the plain and ordinary meaning of a term, reference may be made to a dictionary. See id. ( "If necessary, the plain and ordinary meaning of the word can be ascertained by reference to a dictionary. "). 8 The Legislature created section 125.031, Florida Statutes, in 1971, see chapter 71 -240, section 1, at 1318 -19, Laws of Florida, and, as stated in footnote 6, supra, has amended the stat- ute only once since that time. See Ch. 89 -103, § 1, at 279, Laws of Fla. (increasing time period implicating statute from 24 to 60 months). How- ever, no legislative history surrounding these amendments sheds light on the meaning of the term "approval" as used in the statute. [ * *22] In its opinion, the federal district court de- fined "approve" as "to have or express a favorable opin- ion of or "to accept as satisfactory." Frankenmuth, 10 Fla. L. Weekly Fed. at D341 (quoting Webster's Ninth New Collegiate Dictionary at 98 (Merriam- Webster Inc. 1991)). In addition to the definition adopted by the fed- eral district court, the dictionary definition of "approve" also includes "to give formal or official sanction to." Webster's Tenth Collegiate Dictionary at 57 (Merri- am-Webster Inc. 1996). Thus, the dictionary shows that the term "approve" may consist of either an informal or formal expression of assent. Florida case taw 9 also establishes that an approval or ratification can occur without formal resolution. For example, in Deutsche Credit Corp. v. Peninger, 603 So. 2d 57, 58 (Fla. 5th DCA 1992), the court stated, "Ratifi- cation of an agreement occurs where a person expressly or impliedly adopts an act or contract entered into in his or her behalf by another [ * *23] without authority." Similarly, in City of Panama City, the First District de- termined that the city commission had ratified the city manager's unauthorized termination of a contract be- tween the city and a third party-even though the city commission did not pass a formal resolution terminating the contract -where the city commission knew the reasons for the termination and then voted to award the contract to a third party. See 606 So. 2d at 747; see generally I OA McQuillin, § 29.106 at 82 (stating that ratification of a municipal contract may occur "by the affirmative action of the proper officials, or by any action or non - action which in the circumstances amounts to approval of the contract "); cf. Killearn Properties, Inc. v. City of Tal- lahassee, 366 So. 2d 172 (Fla. 1st DCA 1979) (employ- 10/28/2014 10. B. Page 7 ing doctrine of estoppel to bar city from challenging va- lidity of agreements on grounds of lack of proper formal- ities in the passage [*1021] of such agreements). Asa result, we determine that the term "approval" as used in section 125.031 does not require a board [ * *24] of county commissioners to pass a formal resolution, unless passage of such a resolution is required by the governing law of the county. 10 We do note, however, that several principles must be satisfied before a board of county commissioners may be deemed to have approved an agreement absent formal resolution. 9 See, e.g., State v. Mitro, 700 So. 2d 643, 645 (Fla. 1997) ( "In the absence of a statutory defini- tion, resort may be had to case law or related statutory provisions which define the term .... 11). 10 We recognize that in reaching its decision in City of Panama City, the First District distin- guished the process of ratifying entry into an agreement from the process of ratifying the ter- mination of an agreement. See 606 So. 2d at 747. However, the different policy concerns implicat- ed in those distinguishable processes does not al- ter the conclusion that an approval or ratification of an agreement may occur absent formal resolu- tion where the governing law of the county does not require action by formal resolution. [ * *25] First, we determine that an approval absent formal resolution must be made in compliance with Florida's Sunshine Law, which is of both constitutional and statutory dimension. See art. 1, § 24(b), Fla Const.; § 286.011 (1), Fla. Stat. (1999). Under the Sunshine Law, any meeting at which official acts are to be taken must be open to the public, and no "resolution, rule or formal action shall be considered binding except as taken or made at such meeting." § 286.01 1(1), Fla. Stat. (1999); see also, e.g., Zorc v. City of Vero Beach, 722 So. 2d 891, 896 (Fla. 4th DCA 1998) (interpreting Sunshine Law). As we previously have stated, "The intent of [the Sunshine Law] is to cover any gathering of the members of the Board where the members deal with some matter on which foreseeable action will be taken by the Board." Tolar, 398 So. 2d at 428. Thus, for a board of county commissioners to approve a lease or lease- purchase agreement in accordance with section 125.031, we find it necessary that such approval [ * *26] be made "in the sunshine." If an "approval" by a board of county commissioners of a lease or lease purchase agreement under section 125.031 must be made in accordance with the Sunshine Law, it necessarily follows that any subsequent ratifica- tion of such an agreement must also be made in compli- ance with the Sunshine Law. This is so because we have Packet Page -330- 769 So. 2d 1012, *; 2000 Fla. LEXIS 1889, * *; 25 Fla. L. Weekly S 697 recognized that for a local government to properly ratify a previously executed, unauthorized agreement, the agreement must be ratified "in the same manner ... in which it might have been originally adopted." Ramsey, 139 Fla. at 113, 190 So. at 477; see also Broward County v. Conner, 660 So. 2d 288, 290 (Fla. 4th DCA 1995) (interpreting Sunshine Law) ( "If the county could not have entered into this contract without action taken at a meeting, it necessarily follows that the actions of the county's attorneys could not bind the county to specific performance of a contract in the absence of proper com- mission approval. "). As stated by the First District in City of Panama City, the apparent policy justification [ * *27] for the requirement set forth in Ramsey is that "taxpayers should not be held accountable on a contract unless the contract has been entered into according to the strict letter of the law. Otherwise, corrupt (or merely inept) public officials could subject the public to untold financial liability." 606 So. 2d at 747. Second, in addition to the requirement that a subse- quent approval in the form of ratification be made "in the sunshine" in the same manner that a formal approval would have required, there are several other general principles undergirding the concept of ratification war- ranting our attention. In the vintage opinion of Ball v. Yates, 158 Fla. 521, 527, 29 So. 2d 729, 732 (1946), this Court stated, "Before ratification will be implied of an act of an unauthorized agent it must be made to appear that the principle has been fully informed and that he has approved." In Peninger, 603 So. 2d at 58, the Fifth Dis- trict Court of Appeal expounded upon the general pro- nouncement made by this Court in Ball: [ * *28] [ *1022] An agreement is deemed ratified where the principal has full knowledge of all material facts and circumstances relating to the unauthorized act or transaction at the time of the ratifi- cation. G & M[v. Tropical Music Serv.], 161 So. 2d [556] at 558. See also Ball v. Yates, 158 Fla. 521, 29 So. 2d 729 (1946), cert. den., 332 U.S. 774, 68 S. Ct. 66, 92 L. Ed. 359 (1947); Pedro Realty Inc. v. Silva, 399 So. 2d 367 (Fla. 3d DCA 1981); Bach v. Florida State Bd. of Den- tistry, 378 So. 2d 34 (Fla. 1st DCA 1 979). An affirmative showing of the principal's intent to ratify the act in question is re- quired. [Carolina- Georgia Carpet & Textiles, Inc. v. J Pelloni, 370 So. 2d 450 at 452. Moreover, the issue of whether an agent's act has been ratified by the princi- 10/28/2014 10.B. Page 8 pal is a question of fact. One Hour 'Valet ofAmerica, Inc. v. Keck, 157 So. 2d 83 (Fla. 2d DCA 1963). Regarding the "full knowledge" requirement discussed in Peninger, the First District stated the following in Bach v. Florida State Board of Dentistry, 378 So. 2d 34, 36 -37 (Fla. 1 st DCA 1979): [ * *29] Before one may infer that a principal ratified an unauthorized act of his agent, the evidence must demonstrate that the principal was fully informed and that he approved of the act. Ball v. Yates, 158 Fla. 521, 29 So. 2d 729, 732 (1946). It is generally the rule that the doctrine of constructive knowledge does not apply to bring about ratification. The principal is charged only upon a showing of full knowledge, and not because he had notice which should have caused him to make inquiry, which in turn would have brought to his attention the knowledge of the un- authorized act of the employee. 2 Fla. Jur. 2d, Agency and Employment, § 52 at page 204 (1977).... There is no duty imposed upon the principal to make inquiries as to whether his agent has carried out his re- sponsibilities. The principal "has a right to presume that his agent has followed in- structions, and has not exceeded his au- thority." Oxford Lakeline v. First Nat. Bank, 40 Fla. 349, 24 So. 480, 483 (1898). And, [ * *30] Packet Page -331- [w]henever he is sought to be held liable on the ground of ratification, ei- ther express or implied, it must be shown that he rati- fied upon full knowledge of all material facts, or that he was willfully ignorant, or purposely refrained from seeking information, or that he intended to adopt the unauthorized act at all events, under whatever circumstances. Id. 769 So. 2d 1012, *; 2000 Fla. LEXIS 1889, * *; 25 Fla. L. Weekly S 697 Based on the above principles well established in Florida jurisprudence, we determine that a three -prong test is appropriate for determining whether an af- ter -the -fact "approval," or ratification, has occurred in satisfaction of section 125.031, Florida Statutes. First, a board of county commissioners must have the power to approve the agreement. " See, e.g., P.C.B. Partnership v. City of Largo, 549 So. 2d 738, 740 (Fla. 2d DCA 1989) (determining that city did not have authority to enter into an agreement that effectively contracted away the city's police powers). Second, a board of county commission- ers must ratify an agreement in the same manner in which the agreement would have been [ * *31] initially approved. For example, as we stated above, the approval must be made in accordance with the "Sunshine Law." Additionally, where a charter or ordinance requires a board of county commissioners to take action in a speci- fied manner, such as by passing a formal resolution (un- like the circumstances here), [* 1023] then an af- ter -the -fact approval must satisfy the specified manner to be valid. See Ramsey, 190 So. at 476 -77, 139 Fla. at 111 -13 (involving city charter requiring the city com- mission to take action on certain contracts by ordinance or resolution). Finally, in ratifying the agreement in the same manner in which it initially could have been ap- proved, a board of county commissioners must have full knowledge of the material facts relative to the agreement. As we have not been asked to determine whether a prop- er ratification occurred in this case, we leave that ques- tion open for determination by the Eleventh Circuit based on the principles set forth above. 11 As will be addressed in our discussion con- cerning the second certified question, Escambia County argues that the first prong of this test has not been met here because the Escambia County Board of County Commissioners allegedly did not have the power to initially approve the agreement. Specifically, Escambia County argues that (1) the agreement, based on its nonsubstitution clause, required approval by vot- er referendum due to its alleged practical long -term impact on ad valorem taxes; and (2) the nonsubstitution clause is not severable from the agreement. [ * *32] B. THE SECOND CERTIFIED QUESTION The second certified question presented by the Eleventh Circuit has asked us to determine whether the nonsubstitution clause contained in the underlying 10/28/2014 10.B. Page 9 agreement violates article VII, section 12 of the Florida Constitution, which provides: Counties, school districts, munic- ipalities, special districts and local gov- ernmental bodies with taxing powers may issue bonds, certificates of indebtedness or any form of tax anticipation certifi- cates, payable from ad valorem taxation and maturing more than twelve months after issuance only: (a) to finance or refinance capital projects authorized by law and only when approved by vote of the electors who are owners of freeholds therein not wholly exempt from taxation .... To more accurately reflect the procedural posture and underlying facts of this case, we rephrase the second certified question to read: DOES THE NONSUBSTITUTION CLAUSE IN THE LEASE - PURCHASE AGREEMENT, WHICH REQUIRES UP TO A TWO -YEAR LAPSE IN COMPUTER SERVICES UPON NONAPPROPRIATION, VIOLATE ARTICLE VII, SECTION 12, OF THE FLORIDA CONSTITUTION, [ * *33] EVEN THOUGH THE AGREEMENT ALSO EXPRESSLY DISCLAIMS USE OF REVENUES FROM AD VALOREM TAXATION? After careful consideration, we answer the second certi- fied question, as rephrased, in the affirmative. The 1968 revision to the Florida Constitution, which produced article VII, section 12 of the Florida Constitu- tion, became effective on January 7, 1969. 12 See State v. County of Dade, 234 So. 2d 651, 652 (Fla. 1970). Since that time, we have addressed the constitutional provision on several occasions. Escambia County asserts that our decisions in County of Volusia v. State, 417 So. 2d 968 (Fla. 1982), and Nohrr v. Brevard County Educational Facilities [ *1024] Authority, 247 So. 2d 304 (Fla. 1971), 13 support a finding that the nonsubstitution clause implicates article VII, section 12, while Frankenmuth Packet Page -332- 769 So. 2d 1012, *; 2000 Fla. LEXIS 1889, * *; 25 Fla. L. Weekly S 697 10/28/2014 10.B. Page 10 attempts to distinguish Nohrr and County of Volusia, compelling the lessee to continue to ap- primarily relying on our decisions in Murphy v. City of propriate funds throughout the full lease Port St. Lucie, 666 So. 2d 879 (Fla. 1995); State v. term, thereby rendering the optional fea- School Board of Sarasota County, 561 So. 2d 549, 553 tures of the nonappropriation and nonre- (Fla. 1990); State v. Brevard County, 539 So. 2d 461 newal clauses illusory." Id. [ * *36] This (Fla. 1989); [ * *34] City of Palatka v. State, 440 So. 2d court agrees a non - substitution clause may 1271 (Fla. 1983); and State v. Alachua County, 335 So. render a non - appropriation clause illusory, 2d 554 (Fla. 1976). In federal district court, the parties thereby requiring a lease to undergo Arti- presented arguments similar to those presented here, and the court there determined that the nonsubstitution cle VII, § 12 voter referendum. While clause contained in Paragraph 21 of the agreement implicates Florida's courts have not addressed the issue, article VII, section 12 of the Florida Constitution, and precise several decisions lead to that conclusion. In Nohrr v. Brevard thus the agreement could not have been approved absent County Educational Facilities Authority, a voter referendum. See Frankenmuth, 10 Fla. L. 247 So. 2d 304 (Fla. 1971), [ * *37] the Weekly Fed. at D342. In essence, the court determined court validated non - referendum revenue that the inclusion of the nonsubstitution clause trans- bonds that had been authorized to raise formed the agreement into a long -term certificate of in- money to build educational facilities. The debtedness pledging ad valorem taxes. See id. at D341. court deleted from the bonds, however, In making this determination, the district court engaged certain provisions that created a mortgage in the following analysis: on the property, allowing the bondholders Like many long -term municipal lease to foreclose in the event of default. The court reasoned the mortgage would "mor- agreements, the Unisys master lease con- ally compel" the governing body to levy tains a non - appropriation clause, provid- taxes to avoid foreclosure in the event ing that, if in any given year the govern- bond payments could not be made from ing body fails to appropriate funds to non -ad [ *1025] valorem revenue. Id. make the lease payments, the lease will at 311. In effect, the mortgage provision terminate. (Master Lease P 21). Such amounted to a pledge of ad valorem taxes, non - appropriation or non - renewal clauses which is invalid absent approval by the are essential to prevent long -term munic- electorate. ipal financing arrangements from being classified as debt under state law, thus Similarly in State v. Brevard County, triggering state -law requirements such as 539 So. 2d 461 (Fla. 1989), the court ap- voter referendum. See M. David Gelfand, proved a long -term lease - purchase ar- State & Local Government Debt Financ- rangement which included an annual "re- ing, § 3:17 at 32 (Clark Boardman & Cal- newal option" similar to the annual laghan 1993). non- appropriation clause in the Unisys lease. The court rejected an argument that The Unisys lease [ * *35] also con - the financing arrangement violated Nohrr, tains a non - substitution clause, providing but specifically noted the deal allowed the that, in the event of non - appropriation, the county to "terminate the lease without Lessee agrees not to procure substitute further obligation" in any given year. Id. computer equipment [or equivalent ser- at 463. Thus, the court reasoned, "with its vices] for the remainder of the appropria- annual renewal option' under the lease, tion period and the one following it. [ * *38] the county maintains full budget - (Master Lease P 21). Such clauses are a ary flexibility." common method by which the lessor cre- ates an economic disincentive for the mu- In contrast, a non - substitution clause nicipality to exercise its non - appropriation denies the county "full budgetary flexibil- rights. Gelfand § 3:17 at 32. As one ity" because it renders the commentator has noted, however, "there non - appropriation clause illusory by is considerable doubt about the enforcea- compelling the municipality to make the bility of the non - substitution clause and lease payments or suffer a penalty. The its effect on the validity of the lease." Id. Attorney General of at least one State has at 33. "The inclusion of the opined a non - substitution clause compels nonsubstitution clause may be viewed as lease payments and creates debt. See La. Packet Page -333- sm 10/28/2014 10.B. Page 11 769 So. 2d 1012, *; 2000 Fla. LEX1S 1889, * *; 25 Fla. L. Weekly S 697 Atty Gen. Op. No. 86 -517, 1986 WL Nothing herein shall 236994; constitute a pledge by the Accordingly, the court must address Lessee of the full faith and credit of the Lessee, nor two issues to determine the validity of the does the Lessee pledge any non - substitution clause in this case: (1) ad valorem taxes or other whether the risk of non - substitution would moneys other than moneys morally compel the County Commission lawfully appropriated by to appropriate funds for the lease pay- the County Commission of ments; and (2) whether those funds would Escambia County from come from ad valorem tax dollars. time to time. .. . Lessor A. Moral Compulsion shall [ * *40] not have the make the lease payments to avoid the risk right to require or compel Had funds not been appropriated to the exercise of the ad val- make the Unisys lease payments, the evi- orem taxing power of, or dence is undisputed the consequences of the appropriation of any non - substitution would have been disas- funds by the County trous. The Unisys equipment provided the Commission to obtain the primary means for county payroll and payment or performance of central data processing for the County any of the Lessees obliga- Commission and numerous other county tions created by this offices. At deposition, Flowers made the agreement. following comments regarding 2d at 463 (refusing to apply County non - substitution: [ * *41] of Volusia to a case in which the Q: [ * *39] What would happen? (Addendum P 1). A: If they took the equipment out, Regardless of the above provision, then we would be shut down. We would- the court finds the lease, and in particular n't be able to operate. the non - substitution clause, would inevi- Q: Why is that? tably require the County Commission to appropriate ad valorem tax dollars to A: Because everything was on that make the lease payments. The case is computer. [ *1026] similar to County of Volusia v. (Flowers Deno. at 65). Given these State, 417 So. 2d 968 (Fla. 1982), in facts, the court wastes little time finding which the municipality sought to secure the County Commission would feel mor- bonds by pledging "All legally available ally compelled to appropriate funds to sources of unencumbered county revenue make the lease payments to avoid the risk other than ad valorem taxes." The su- of running county government without a preme court reasoned this pledge, along central data processing ability for up to with Volusia County's promise to do all two years. In this regard, the things necessary to continue to receive the non - appropriation clause is rendered illu- non -ad valorem revenue, would inevitably sory and the lease creates a multi -year lead to higher ad valorem taxes during the debt. life of the bonds. The court denied valida- tion, reasoning, "that which may not be B. Ad Valorem Taxes done directly may not be done indirectly." A municipal debt does not trigger Ar- Id. at 972.; cf. Brevard County, 539 So. ticle VII, § 12, however, unless it pledges 2d at 463 (refusing to apply County ad valorem tax dollars as its source of [ * *41] of Volusia to a case in which the payment. E.g. State v. School Bd of municipality, unlike Escambia County in Sarasota County, 561 So. 2d 549, 552 this case, "reserved the right to terminate (Fla. 1990). In this case, the addendum to the lease without further obliga- the master lease specifies no ad valorem tion. ")County of Volusia applies squarely taxes are pledged: to these facts. The size of the lease pay- ments together with the consequences of Packet Page -334- 769 So. 2d 1012, *; 2000 Fla. LEXIS 1889, * *; 25 Fla. L. Weekly S 697 non - substitution indicate the County Commission would inevitably be forced to spend ad valorem taxes dollars to fund this lease. The addendum clause pledging otherwise is illusory. For these reasons, the court finds the non - substitution clause violates Article VII, § 12 of the Florida Constitution and is therefore unenforcea- ble. Frankenmuth, 10 Fla. L. Weekly Fed. at D341 -42 (footnote omitted). 12 The predecessor constitutional provision to article VII, section 12, was article IX, section 6 of the Constitution of 1885, which was effective from 1930 until January 7, 1969. See State v. County of Dade, 234 So. 2d 651, 654 (Fla. 1970). That section provided: The Legislature shall have power to provide for issuing State bonds only for the purpose of re- pelling invasion or suppressing insurrection, and the Counties, Districts, or Municipalities of the State of Florida shall have power to issue bonds only after the same shall have been approved by a majority of the votes cast in an election in which a majority of the freeholders who are qualified electors residing in such Counties, Districts, or Municipalities shall participate, to be held in the man- ner to be prescribed by law; but the provisions of this act shall not apply to the refunding of bonds issued exclusively for the purpose of refunding of the bonds or the interest thereon of such Counties. Districts, or Municipalities. Art. IX, § 6, Fla. Const. (1885). In numerous decisions, this Court held that various kinds of debts were not "bonds" for the purposes of the referendum requirement. See, e.g., State v. Miami Beach Redevelopment Agency, 392 So. 2d 875, 895 -98 (Fla. 1980) (discussing this Court's cases const ruing the predecessor constitutional provi- sion); see generally Patricia M. Lee, Note, Bond 10/28/2014 10. B. Page 12 Financing and the Referendum Requirement: Harmless Creative Financing or Assault on the Constitution ?, 20 Stet. L. Rev. 989, 992 -98 (199 1) (same). 13 In State v. School Board of Sarasota Coun- ty, 561 So. 2d 549, 553 (Fla. 1990), this Court in- dicated that our prior decision in Nohrr construed the predecessor to article VII, section 12 of the Florida Constitution. However, after reviewing the opinion in Nohrr, it is clear that (1) the facts in that case took place after the 1968 constitu- tional revision became effective; and (2) this Court was construing the new constitutional pro- vision in that case. We agree with the federal district court's thorough analysis regarding the nonsubstitution clause in the pre- sent agreement. While the addendum to the master lease agreement states that there is to be no pledge of ad val- orem taxes to fund the payments due under the agree- ment, and further disclaims any right to compel the pro- curement of ad valorem taxes, this is not a case where there is a pledge of a specifically demarcated source of revenue to satisfy the underlying obligation. See Murphy, 666 So. 2d at 881 [ * *42] (upholding bond validation where non- ad valorem taxes were pledged as a supple- ment to specifically demarcated source of revenue); City of Palatka, 440 So. 2d at 1273 (validating bond where two specific non -ad valorem sources of revenue were pledged); Alachua County, 335 So. 2d at 556 -58 (vali- dating bonds funded by pledge of revenue sharing funds and race track proceeds). More importantly, this is not a case where the county has retained "full budgetary flexi- bility." See School Board of Sarasota County, 561 So. 2d at 552 -53 (noting that school board could maintain "full budgetary flexibility" under terms of agreement); " Bre- vard County, 539 So. 2d at 464 (noting that "annual re- newal option" under lease- purchase agreement would allow county to maintain "full budgetary flexibility"). Instead, due to the expense and functionality of the computer equipment covered by the agreement here, the nonsubstitution clause interrelates with other lease provi- sions, see County of Volusia, 417 So. 2d at 972, to "mor- ally compel" the county to pledge ad valorem taxes to fulfill the obligations of the lease. See [ * *43] Nohrr, 247 So. 2d at 311. Accordingly, we answer the second certified question, as rephrased, in the affirmative. 't 14 In School Board of Sarasota County, we noted that the school board's failure to appropri- ate funds would result in "lease penalties," but that even with such penalties, the board main- tained its "full budgetary flexibility." See 561 So. 2d at 552 -53. As set forth in our opinion in that case, the lease penalties included either purchas- ing the constructed facilities or surrendering pos- Packet Page -335- 10/28/2014 103. Page 13 769 So. 2d 1012, *; 2000 Fla. LEXIS 1889, * *; 25 Fla, L. Weekly S 697 session of the facilities and the land upon which those facilities stood for the remainder of the lease term. See id. at 551. We emphasized, how- ever, that the school board was "free to substitute other facilities for those surrendered." See id. Clearly, the presence of a nonsubstitution clause here distinguishes this case from our decision in School Board of Sarasota County, insofar as "full budgetary flexibility" is concerned. 15 The federal district court determined that the nonsubstitution clause is severable from the remainder of the agreement, seeFrankenmuth, 10 Fla. L. Weekly Fed. at D342, but the Eleventh Circuit has not asked us to make a determination regarding severability. We decline to address the severability issue here, given that the issue is not novel and has not been fully briefed in this Court. We do note, however, that if the nonsubstitution clause is not severable from the remainder of the agreement, then the entire agreement must be in- validated as violative of article VII, section 12 of the Florida Constitution. [ * *44] III. CONCLUSION As we have analyzed, the first certified question is answered in the affirmative [*1027] upon our deter- mination that a board of county commissioners may ap- prove in the form of ratification a lease- purchase agree- ment under section 125.031, Florida Statutes, even ab- sent formal resolution, where the board is not required by local ordinance or charter to take action by formal reso- lution. Further, we have established a three -prong test to guide the determination of whether an approval without formal resolution has occurred. Finally, we have re- sponded to the second certified question as rephrased in the affirmative upon the determination that, based on the particular facts in this case, the nonsubstitution clause implicates article VII, section 12 of the Florida Constitu- tion. Accordingly, we return the record in this case to the United States Court of Appeals for the Eleventh Circuit. It is so ordered. WELLS, C.J., and SHAW, HARDING, ANSTEAD, PARIENTE and QUINCE, JJ., concur. Packet Page -336- Or LexisNexis@ 10/28/2014 10.B. Page l FOCUS - 4 of 24 DOCUMENTS FRANKENMUTH MUTUAL INSURANCE COMPANY, Plaintiff - Appellee, Cross - Appellant, versus ESCAMBIA COUNTY, FLORIDA, Defendant - Appellant, Cross - Appellee. No. 01 -12976 UNITED STATES COURT OF APPEALS FOR THE ELEVENTH CIRCUIT 289 F.3d 723; 2002 U.S. App. LEXIS 7493; 15 Fla. L. Weekly Fed. C 507 April 24, 2002, Decided April 24, 2002, Filed SUBSEQUENT HISTORY: Appeal after remand at Frankenmuth Mut. Ins. v. Magaha, 2003 U.S. App. LEXIS 27185 (11th Cir., Dec. I6, 2003) PRIOR HISTORY: [ * *1] Appeals from the United States District Court for the Northern District of Florida. D. C. Docket No. 95- 30412 -CV -3 -LAC. Judge: Lacey A. Collier. Frankenmuth Mut. Ins. Corp. v. Magaha, 1996 U.S. Dist. LEXIS 15930 (N.D. Fla. 1996). Frankenmuth Mut. Ins. Corp. v. Magaha, 1996 U.S. Dist. LEXIS 15930 (N.D. Fla., Aug. 30, 1996) DISPOSITION: Affirmed in part, vacated and re- manded in part. COUNSEL: For County of Escambia, Florida, Appel- lant: Tucker, David G., Escambia County Attorney's Of- fice, Pensacola, FL. For Frankenmuth Mutual Insurance Company, Appel- lee: Westmoreland, J. Lofton, Moore, Hill & West- moreland, Pensacola, FL. Beall, Charles Franklin Jr., Moore, Hill, Westmoreland, Hook & Bolton, P.A., Pen- sacola, FL. JUDGES: Before BARKETT, HULL and KRAVITCH, Circuit Judges. OPINION BY: BARKETT OPINION [ *725] BARKETT, Circuit Judge: The Board of County Commissioners of Escambia County, Florida ( "the County") appeals from a summary judgment in favor of Frankenmuth Mutual Insurance Company ( "Frankenmuth "). The summary judgment order declared enforceable a computer lease - purchase agreement ( "the Lease ") between the County and Unisys Leasing Corporation, Frankenmuth's predecessor in interest. Frankenmuth cross - appeals the district court's denial of its motion for costs and attorneys' fees. We AFFIRM the summary judgment declaring the Lease enforceable and VACATE the denial of Frankenmuth's motion for attorneys' fees and costs. FACTS In 1992, the Escambia County Comptroller, Joe Flowers, signed a lease - purchase agreement with Unisys Leasing Corporation to lease a mainframe computer. In subsequent years, he added additional computer equip- ment and an imaging system to the Lease under a series of lease schedules. Paragraph 21 of the lease- purchase agreement contained a "non- appropriation clause, [ * *2] " which provided that the agreement would terminate in any given [ *726] year if the "legislative body or funding authority" should fail to appropriate funds to make the Lease payments. ' Additionally, paragraph 21 contained a non - substitution clause, which provided that in the event the County refused to appropriate the requi- site funds ( "non- appropriation "), the County agreed not to purchase or rent any substitute computer equipment for the balance of the appropriation period and for one full period following the termination of the agreement. In Packet Page -337- 289 F.3d 723, *; 2002 U.S. App. LEXIS 7493, * *; 15 Fla. L. Weekly Fed. C 507 a separate addendum, the agreement provided that noth- ing in the Lease would be construed to constitute a pledge of ad valorem taxes and that, in the event of de- fault, the lessor had no right to compel the County to appropriate funds to make the lease payments. 1 The non - appropriation clause allowed the County to be released from the lease if certain conditions were met, including lack of funding for the lease from any source, proper notice, re- turn of equipment in substantially the same con- dition in which it was. received, payment of any amount due under the lease during the appropria- tions period in which the default occurred, for- feiture of any security deposits, and payment of any termination charges. [ * *3] Flowers made scheduled payments under the lease - purchase agreement for several years without incident, during which the computer equipment was used for a variety of municipal functions, including county payroll and central data processing services, and to ser- vice the Road, Mass Transit and Solid Waste Depart- ments. For the years 1992, 1993, and 1994, Flowers submitted his budget requests to the County and included in the Comptroller's budget a line item for "Debt Service on Computer Equipment." 2 Each year the County ap- proved in excess of $ 300,000.00 to cover this expendi- ture without any specific inquiry into the details of the lease agreement. During this period, Unisys conveyed its interest in the Lease to Chicorp Corporation, and Chicorp subsequently conveyed its interest in the Lease to Frankenmuth. 2 The budgets that Flowers submitted request- ed $ 301,563.00 for the computer leases in 1992, $ 304,561.00 in 1993, and $ 304,113.00 in 1994. In early 1994, the County began studying the advis- ability of a county -wide [ * *4] computer network. Flowers suggested integrating the County's computer network with the Comptroller's system, and provided the County with information about the Unisys equipment, although he did not send to the County specific infor- mation regarding the terms of the lease with Unisys. The County affirmed the decision to integrate the systems at a public meeting held on June 28, 1994. Later in 1994, the County lost millions of dollars in bad derivative investments made by Flowers' office. Flowers was criminally indicted for various acts of mal- feasance, one of which was his decision to enter into the Lease with Unisys without County approval. Flowers pled no contest and resigned from office. In 1995, the Florida legislature abolished the Escambia County Office of the Comptroller, and the Escambia County Clerk of the Circuit Court, Ernie Lee Magaha, became responsi- 10/28/2014 10.B. Page 2 ble for the constitutional duties formerly held by the Of- fice of Comptroller. Magaha and the County reviewed the Lease and determined that the County should reject the Lease because the Unisys equipment was too old, expensive, and ineffective to serve the County's needs. Consequently, in mid -1995, the County notified Frank- enmuth [ * *5] that it would not make its remaining Lease payments for that year and that the Lease was void and unenforceable because Flowers had not been author- ized to enter into the agreement [ *727] without Coun- ty approval, and he had failed to secure such approval. In September 1995, Frankenmuth brought this lawsuit seeking both a declaration that the Lease was valid and enforceable and an injunction prohibiting the County from breaching the agreement. During the dis- covery period, the County purchased a replacement computer system, and Frankenmuth amended its claim to seek only declaratory relief. All parties moved for summary judgment. The district court ruled in part for Frankenmuth, finding that although the non - substitution clause in the Lease was void and unen- forceable under Article VII, § 12 of the Florida Constitu- tion, ' the clause was severable, and, because the County had ratified the Lease, the contract was enforceable without the non - substitution clause. 3 Article VII, § 12, prohibits ad valorem taxes from being used for this purpose. It reads: Counties, school districts, mu- nicipalities, special districts and local governmental bodies with taxing powers may issue bonds, certificates of indebtedness or any form of tax anticipation certifi- cates, payable from ad valorem taxation and maturing more than twelve months after issuance only: (a) to finance or refinance capital projects authorized by law and only when approved by vote of the electors who are owners of freeholds therein not wholly ex- empt from taxation; or (b) to refund outstanding bonds and interest and redemption premium thereon at a lower net average interest cost rate. [ * *61 The County appealed the district court's de- cision and this Court certified two questions to the Flor- ida Supreme Court, namely: (1) whether a county board Packet Page -338- 289 F.3d 723, *; 2002 U.S. App. LEXIS 7493, * *; 15 Fla. L. Weekly Fed. C 507 of commissioners may approve a lease - purchase agree- ment under Fla. Stat. ch. 125.031 absent formal resolu- tion, ' and, if so, what standards guide consideration of whether such an approval has occurred; and (2) whether the non - substitution clause contained in the Lease vio- lates Article VII, § 12 of the Florida Constitution. Frankenmuth v. Magaha, 769 So. 2d 1012 (Fla. 2000). The Florida Supreme Court ruled that a county board may approve an agreement absent an express resolution, and outlined a three -part test for determining whether, under Fla. Stat. ch. 125.031, a Board has ratified an agreement after the fact ( "the Frankenmuth test "). The Florida Supreme Court also ruled that the non - substitution clause violated the Florida Constitution and was therefore unenforceable. 5 4 Fla. Stat. ch. 125.031 gives the County gen- eral authority to contract for goods, services, and equipment needed for a public purpose as long as the contract does not exceed thirty years. [ * *7] 5 The Florida Supreme Court explained that "the inclusion of the nonsubstitution clause may be viewed as compelling the lessee to continue to appropriate funds throughout the full lease term, thereby rendering the optional features of the nonappropriation and nonrenewal clauses illuso- ry.... [A] non - substitution clause may render a non - appropriation clause illusory, thereby re- quiring a lease to undergo Article VII, § 12 voter referendum." Frankenmuth, 769 So. 2d at 1024. In accordance with the Florida Supreme Court's de- cision, this Court vacated the district court's original summary judgment in favor of Frankenmuth, and re- manded the case for a determination of whether the County had ratified the agreement under the Franken- muth test, and was therefore liable under the contract. On remand, the district court again held that the uncon- stitutional non - substitution clause was severable, and therefore did not invalidate the entire lease. The court concluded that the County had ratified the agreement under the Frankenmuth test and that, accordingly, the contract was enforceable [ * *8] against the county. The district court further held that neither Escambia nor Frankenmuth was entitled to attorneys' [ *728] fees. The County now appeals, arguing that the district court erred in concluding both that the non - substitution clause was severable and that the county had ratified the lease agreement. Frankenmuth cross - appeals from the denial of its motion for attorneys' fees and costs. The interpretation of an agreement under traditional contract principles is a question of law subject to de novo review. See Brewer v. Muscle Shoals Bd. of Educ., 790 F.2d 1515, 1519 (11th Cir. 1986). We review a district 10/28/2014 103. Page 3 court's decision interpreting a contractual attorneys' fee provision de novo. BankAtlantic v. Blythe Eastman Paine Webber, Inc., 955 F.2d 1467, 1477 (11th Cir. 1992). DISCUSSION I. The County's Appeal The Florida Supreme Court held that the non - substitution clause in the Lease violates the Florida Constitution. Frankenmuth, 769 So. 2d at 1023. Ac- cordingly, unless the non - substitution clause is severable, the Lease is not enforceable. The County first argues that the district court erred in [ * *9] concluding that the Lease's non - substitution clause is severable. The County further argues that, even if the non - substitution clause is severable, the district court erred in finding that the County ratified the Lease. We first address the severabil- ity question. A. Whether the Lease's Non - Substitution Clause Is Severable In determining whether a contract provision is sev- erable, Florida courts look to the entirety of the agree- ment. Wilderness Country Club v. Groves, 458 So. 2d 769, 771 (Fla. 2d Dist. Ct. App. 1984) ( "[A] contract is indivisible where the entire fulfillment of the contract is contemplated by the parties as the basis of the arrange- ment.") (quoting Local No. 234 v. Henley & Beckwith, 66 So. 2d 818 (Fla. 1953)). On review of a bilateral con- tract' such as the one at issue here, the governing rule is that a bilateral contract is severable where the illegal portion of the contract does not go to its essence, and where, with the il- legal portion eliminated, there still re- mains of the contract valid legal promises on one side which are wholly supported by valid legal promises on the other. Williston on Contracts, [ * *10] rev. ed., Vol. 6, § 1782; see also Vineberg v. Brunswick Corp., 391 F.2d 184, 186 (5th Cir. 1968) ( "an illegal contract provision, or one contrary to public policy, when invalidated, will be severed from the remainder of the contract if it is pos- sible to do so without leaving the remainder of the con- tract meaningless.") '; Wilderness, 458 So. 2d at 771 (a bilateral contract is severable where the illegal provision does not go to its essence). Whether a contract is entire or divisible depends upon the intention of the parties. Ireland v. Craggs, 56 F.2d 785 (5th Cir. 1932). The par- ties' intention is a matter that may be determined "by a fair construction of the terms and provisions of the con- Packet Page -339- 289 F.3d 723, *; 2002 U.S. App. LEXIS 7493, * *; 15 Fla. L. Weekly Fed. C 507 tract itself, and by the subject matter to which it has ref- erence." 12 Am. Jur. 2d, Contracts, § 415. 6 Black's Law Dictionary defines a bilateral contract as "[a] contract in which each party promises a performance, so that each party is an obligor on that party's own promise and an obli- gee on the other's promise." Black's Law Dic- tionary 319 (7th ed. 1999). [ * *11] 7 In Bonner v. Prichard, 661 F.2d 1206, 1209 (11th Cit. 198 1) (en banc), the Eleventh Circuit adopted as binding precedent all Fifth Circuit de- cisions handed down prior to the close of busi- ness on September 30, 1981. [ *729] Here, the fact that the contract itself con- tains a severability provision demonstrates that the par- ties intended for the contract to be severable. ° Further- more, the non - substitution clause does not go to the es- sence of the contract. The primary promises between the parties remain unchanged in the absence of this clause: the County agreed to pay in excess of $ 300,000.00 each year to lease the computer equipment, and Franken- muth and Unysis continued to supply the City with offi- cial title to the property and use of the equipment for the lease term. In this case, the non - substitution clause did not go to the essence of the contract between the parties. The essential terms remain intact without the non - substitution clause and the remainder of the contract remains meaningful and viable. Thus, the district court did not err in determining that the non - substitution [ * *12] clause in this lease was severable. 8 Paragraph 30 of the contract reads: "Severa- bility: Any provision of this Lease which is pro- hibited or unenforceable in any jurisdiction shall, as to such jurisdiction, be ineffective to the extent of such prohibition or unenforceability, without invalidating the remaining provisions hereof. To the extent permitted by applicable law, Lessee hereby waives any provision of law which pro- hibits or renders unenforceable any provision hereof in any respect." Having found that the district court correctly deter- mined that the non - substitution clause was severable, we turn to the question of whether the county ratified the lease - purchase agreement. B. Whether the County Ratified the Lease Purchase Agreement In Frankenmuth v. Magaha, the Florida Supreme Court established a three -part test to determine whether a county has ratified an agreement within the definition of Fla. Stat. ch. 125.031: 10/28/2014 10.B. First, a board of county commissioners must have the power to approve [ * *13] the agreement. Second, a board of county commissioners must ratify [the] . . . agreement in the same manner in which the agreement would have been initially approved. For example, as we stated above, the approval must be made in ac- cordance with the "Sunshine Law." Addi- tionally, where a charter or ordinance re- quires a board of county commissioners to take action in a specified manner, such as by passing a formal resolution (unlike the circumstances here), then an after- the -fact approval must satisfy the specified man- ner to be valid. Finally, in ratifying the agreement in the same manner in which it initially could have been approved, a board of county commissioners must have full knowledge of the material facts rela- tive to the agreement. Page 4 Frankenmuth, 769 So. 2d at 1022 -23. The County ar- gues that none of the three prongs of the Frankenmuth test can be satisfied, and thus, that the district court erro- neously concluded that the County ratified the agree- ment. We discuss each part of the test in turn. 1. Whether the County Had Authority to Enter into the Lease The County's only argument regarding the first prong of the Frankenmuth test is that the [ * *14] County did not have the authority to enter into the Lease because the non - substitution clause in the agreement violated Article VII, § 12 of the Florida Constitution. In other words, the County argues that it could not have ratified the contract because it could not have ratified the non - substitution clause absent a voter referendum as required by Article VII, § 12 of the Florida Constitution. As discussed in Part A, supra, we [ *730] agree with Frankenmuth that the illegal lease term was a severable or non - essential part of the agreement, and therefore the County could have approved the agreement pursuant to its authority under Fla. Stat. ch. 125.031. We recognize that in Frankenmuth, the Florida Supreme Court indi- cated that a government entity commits an ultra vires act when it enters into a contract that violates its constitu- tional obligations, and in this case the Florida Supreme Court concluded that the non - substitution clause con- flicted with the constitutional requirement that the County conduct a voter referendum before entering into a contract that would require a levy of taxes to satisfy its obligations. See Frankenmuth, 769 So. 2d at 1022 (ex- Packet Page -340- 289 F.3d 723, *; 2002 U.S. App. LEXIS 7493, * *; 15 Fla. L. Weekly Fed. C 507 plaining that [ * *15] a city government may not enter into an agreement that purports to contract away the city's police powers); P.C.B. Partnership v. City of Lar- go, 549 So. 2d 738, 740 (Fla. 2nd Dist. Ct. App. 1989) (same). However, unlike P.C.B., where the purpose of the contract was itself unconstitutional, the unconstitu- tional non - substitution clause here was not a central part of the Lease. Here, the Lease payment terms and sched- ule were the central parts of the agreement. The non - substitution clause merely served as a supplemen- tary penalty provision that was designed to discourage the County from deciding to cancel the lease before its full term. Therefore, the district court properly ruled that the County's ratification of the agreement was within the County's authority under Fla. Stat. ch. 125.031, and that Frankenmuth had satisfied its burden under the first prong of the ratification test. 2. Whether the County Ratified the Agreement in the Same Manner in which the Agreement Would Have Been Initially Approved The district court concluded that the only statutory requirement necessary for the County to lawfully ap- prove the Lease in the first instance was compliance [ * *16] with the Florida Sunshine law. Because the County reviewed the lease arrangement and agreed to continue using the leased computer systems at public meetings in May and June 1994, the district court con- cluded that the County had complied with the Sunshine Law. We find no error in this conclusion. Florida law does not require that the County issue a formal resolution to enter into a lease agreement. Con- ceding that no rule requires that a contract be approved by formal vote or resolution, the County nonetheless argues that common law requires some functional equiv- alent to establish that the County intended to adopt the lease - purchase agreement. However, the Florida Su- preme Court has not articulated any specific requirement for such a functional equivalent. Indeed, in explaining the second prong of the Frankenmuth test, the Florida Supreme Court stated: In its opinion, the federal district court defined "approve" as "to have or express a favorable opinion of or "to accept as sat- isfactory." In addition to the definition adopted by the federal district court, the dictionary definition of "approve" also in- cludes "to give formal or official sanction to." Thus, the dictionary [ * *17] shows that the term "approve" may consist of ei- ther an informal or formal expression of assent. 10/28/2014 10. B. Page 5 Frankenmuth, 769 So. 2d at 1020 (internal citations omitted). The County voted in June 1994 to adopt a computer networking plan that used the leased equip- ment. Whether deemed to be a formal or informal ex- pression, there is no question that this action signified the County's assent to the use of the leased equipment. [ *731] The County, however, argues that before it can assent to any contract, either formally or informally, Florida law requires that the specific terms and condi- tions of the contract be presented to the county commis- sion at its public meeting. We are unable to find support in the cases cited by the County, or in Florida law gener- ally, for such a proposition. For example, the County's reliance on Hoskins v. City of Orlando, 51 F.2d 901 (5th Cir. 193 1) is misplaced. In Hoskins, the mayor of the city of Orlando had signed a lease for an apartment building. Id. at 902. That lease was later repudiated by the city. Id. The court invalidated the lease because it had not been made for a legitimate municipal purpose and was [ * *18] thus beyond the city's power. Id. at 904 -05. Further- more, unlike the case at bar, the lease at issue in Hoskins involved real property and thus implicated specific stat- utory requirements, including the unanimous vote of the city council. Id. While the city council had initially ap- proved the lease unanimously, the lease ultimately signed by the mayor was so different from the original lease "as to amount to another transaction." Id. at 906. Ramsey v. City of Kissimmee, 190 So. 474 (Fla. 1939), is likewise inapplicable. There, the court held that the city had not ratified an engineering contract because the city charter expressly required that all such contracts "be evidenced by resolution or ordinance." 139 Fla. at 112. Thus, ratification under that city charter was not possible absent formal resolution. There is no evidence in this case that Escambia County's Code requires a sim- ilar formal resolution to approve or ratify a contract. Frankenmuth, 769 So. 2d at 1021. B 9 The County also relies on Town of Madison v. Newsome, 39 Fla. 149, 22 So. 270 (Fla. 1897), which is likewise inapposite. The Newsome Court rejected an argument that the town had ratified a fixed -term employment contract for a night watchman. In that case, the town council had continued to approve the item listed as the watchman's compensation each month. However, this was the same compensation which had been paid to each of the plaintiffs predecessor night watchmen who had not been employed under a fixed -term contract and there had been nothing in the record by which the council could have real- ized that there had been any change in the status of the night watchman solely from his monthly Packet Page -341- 289 F.3d 723, *;2002 U.S. App. LEXIS 7493, * *; 15 Fla. L. Weekly Fed. C 507 compensation. Newsome turns on a question of knowledge, the third prong of the Frankenmuth test, rather than the manner of ratification, the second prong. [ * *19] We conclude that the district court did not err in determining that the County's ratification of the lease complied with the Florida Sunshine Law and that such compliance was the only statutory requirement necessary for the County to lawfully approve a contract. Since the Board in 1994 initially considered whether to integrate the Unisys system into its new computer net- work at a public meeting, and ultimately agreed to adopt a technology plan that included this equipment at a pub- lic meeting, the approval process satisfied the Sunshine Law's requirements. 11 Thus, the district court did not err in finding that the [ *732] County had informally or implicitly adopted the lease agreement at these public meetings "in the same manner in which the agreement would have been initially approved." 10 The County alternatively argues that the 1994 meetings cannot be used to satisfy the Sun- shine Law requirement, as the County was not aware of all of the material terms of the lease purchase agreements at these meetings and, con- sequently, they do not count as part of the formal review process. This argument, however, misses the mark. The Sunshine Law requires only that the approval of the lease occur in public and has no relevance to the level of information that the County must have in order to enter into a con- tractual agreement. The inquiry into whether the County was aware of the material terms of the agreement is more properly considered under the third prong of the ratification test. Franken- muth, 769 So. 2d at 1022. [ * *20] 3. Whether the County Was Aware of the Material Terms of the Lease The final prong of the Frankenmuth test requires the Board to have been aware of the agreement's material terms at the time it adopted or accepted the lease agree- ment. Frankenmuth, 769 So. 2d at 1022 -23 ("whenever. .. [an entity] is sought to be held liable on the ground of ratification, either express or implied, it must be shown that he ratified upon full knowledge of all material facts. "). The district court concluded that the County had "full knowledge of the material terms" of the computer lease because: (1) over a three year period, the County had approved the Comptroller's budget, which consist- ently included a line item requesting funding for the lease payments; (2) the County had voted to change its technology plan to include the Unisys computer systems; and (3) in two separate audits, an independent auditing 10/28/2014 10. B. Page 6 company had informed the County that it appeared that an official in its employ had entered into an unauthorized lease, and the County failed to investigate or repudiate the lease. The County argues that it was not aware of all of the material terms of the lease - purchase [ * *21] agreement because: (1) it was unaware of the non - substitution clause; (2) some equipment and pricing terms were added to the agreement after the 1994 meet- ings; and (3) it voted to use the computer systems with- out knowledge of the high financing costs associated with the lease agreement. The record reflects that between 1993 and 1994, the County was fully aware of the equipment and costs asso- ciated with the lease. Specifically, in August 1993, Flowers sent the Board Chairman and members of the Board a letter informing them about the installation of the Unisys mainframe computer, describing the comput- er's components, and disclosing his relationship with Unisys. Later, in May 1994, Flowers sent the County Board a letter indicating that the equipment had been updated, and suggesting that the County integrate his computers with the County's other computers to create an area network. By the June 1994 Commission meeting, when the Commission affirmed the plan to integrate the Comptroller's computer system into the County's net- work, the County Commissioners knew that Flowers had acquired new computer equipment and they knew about the characteristics of that equipment. Moreover, the County [ * *22] approved budget expenditures to pay the Lease for three consecutive years between 1992 and 1994, and therefore generally knew about the Lease's costs. Although the County correctly points out that the costs that Flowers budgeted for computer equipment before Flowers signed the Unisys Lease were substan- tially similar to the cost budgeted after he signed that particular lease, there is no question that the Commission was aware of the new lease because Flowers informed the County that he had acquired new computer equip- ment in his letter of August 1993. We are satisfied that the evidence supports the con- clusion that the County was aware of the material terms of the Lease, both because of the information specifically presented to the Commission and because the actual Lease was at all times available to the Commission for reference. While Frankenmuth stated that the ratifying body "is charged only upon a showing of full knowledge" and not because it had information before it that should have prompted an inquiry, it further recog- nized [ *733] that sometimes a petitioner can show that a party ratified an agreement because he "was willfully ignorant, or purposely refrained from seeking infor- mation, [ * *23] or that he intended to adopt the unau- thorized act [or agreement] at all events, under whatever circumstances." Frankenmuth, 769 So. 2d at 1022 (em- Packet Page -342- 289 F.3d 723, *; 2002 U.S. App. LEXIS 7493, * *; 15 Fla. L. Weekly Fed. C 507 phasis added). The evidence in this case suggests that the County intended to adopt the Lease regardless of its terms, as it made a long term commitment to use the equipment when it integrated the system into its network without inquiring into the Lease's specific financing re- quirements or penalties. Also, the County consistently granted the Comptroller funds to make the Lease pay- ments for the three years before this dispute, and only challenged the arrangement after discovering that Flow- ers had committed other errors in running the Comptrol- ler's office and deciding that he should be removed. Ap- proval of the Comptroller's budget alone may not have been enough to prove an intent to ratify the lease agree- ment, particularly given the similarity of the pre- and post- Unisys lease budget requests. Nevertheless, the budget approval, combined with the facts that the County knew Flowers had acquired a new computer system and agreed to integrate this system into its own computer system, is sufficient to prove intent to ratify. [ * *24] In sum, the evidence clearly supports the conclusion that the County intended to be bound by the agreement. Con- sequently, the Board's actions show that it made itself aware of the material aspects of the agreement that it believed were of primary concern, and therefore its ac- tions satisfy the third part of the Frankenmuth test. 11. Frankenmuth's Cross Appeal In its cross - appeal, Frankenmuth argues that the district court erred by using a statutory "prevailing party" analysis to deny its motion for attorneys' fees and costs. Frankenmuth argues that it was entitled to attorneys' fees and costs under the terms of the lease and that the lease grants attorneys' fees under a less stringent standard than the statutory "prevailing party" test. Paragraph 6 of the lease agreement provides that "Lessee shall pay Les- sor all costs and expenses, including reasonable attor- neys' fees, incurred by Lessor in enforcing any terms, conditions, or provisions of this Lease." In denying Frankenmuth's request for attorneys' fees, the court made no reference to the fee - shifting provision contained in the lease. The court simply stated, "it is further the judgment of this Court that neither [ * *25] Plaintiff nor 10/28/2014 10.B. Page 7 Defendant Escambia County has prevailed in this action for the purposes of an award of attorneys' fees and costs." Under Florida law, a "contractual attorney's fee pro- vision must be strictly construed." B & H Constr. & Supply Co. v. District Bd. of Trustees of Tallahassee Cmty. Coll., Fla., 542 So. 2d 382, 387 (Fla. 4th Dist. Ct. App. 1989). Determining whether to grant fees pursuant to a contractual provision is a separate and distinct in- quiry from the statutory "prevailing party" analysis that is otherwise used to disburse fee awards. Fixel Enter- prises v. Theis, 524 So. 2d 1015 (Fla. 1988) (refusing to apply prevailing party standard when contract granted attorneys' fees to "prevailing party" because contract standard was separate and distinct from statutory pre- vailing party inquiry); First Atlantic Bldg. Corp. v. Neubauer Constr. Co., 352 So. 2d 103 (Fla. 4th Dist. Ct. App. 1977) (recognizing that attorneys' fee provision in a contract provided for a different standard than the pre- vailing party analysis). We review the district court's denial of attorneys' fees for abuse of discretion. In re Application to Ad- judge Trinity [ *734] Industries, Inc., 876 F.2d 1485, 1496 (11th Cir. 1989). [ * *26] From the district court's brief discussion of this issue, it is impossible to deter- mine whether the court erroneously relied on the statu- tory prevailing party standard or properly applied the contract terms in rejecting Frankenmuth's request for fees. Id. (remanding issue of denial of fees because "it is impossible for us to discern the correctness of the district court's judgment "). We therefore remand for determina- tion of whether Frankenmuth is entitled to attorneys' fees pursuant to the lease provision. CONCLUSION In summary, we AFFIRM the summary judgment in favor of Frankenmuth but VACATE and REMAND the district court's decision denying Frankenmuth at- torneys' fees and costs for clarification. Packet Page -343- IV LexisNexis@ G. R. RAMSEY AND A. B. HERNDON, Co- partners Doing Business as Ram- sey- Herndon & Company, v. CITY OF KISSIMMEE [NO DOCKET NUMBER] SUPREME COURT OF FLORIDA, Division B 139 Fla. 107; 190 So. 474; 1939 Fla. LEXIS 1631 July 7, 1939 PRIOR HISTORY: [ * * *1] A Writ of Error from the Circuit Court for Osceola County, Frank A. Smith, Judge. COUNSEL: Ellis F. Davis and Dickinson & Dickinson, for Plaintiffs in Error; O. S. Thacker and G. P. Garrett, for Defendant in Error. JUDGES: WHITFIELD, P.J., and BROWN and CHAPMAN, J.J., concur; TERRELL, C.J., concurs in opinion and judgment; Justices BUFORD and THOMAS not participating as authorized by Section 4687, Com- piled General Laws of 1927, and Rule 21 -A of the Rules of this Court. OPINION [* *475] [ *108] PerCuriam. This is the second appearance of this case here. For its former appearance see Ramsey v. City of Kissimmee, 111 Fla. 387, 149 So. 553. On December 5, 1927, plaintiffs filed their decharation embodying a special count, and four com- 10/28/2014 10.B. Page 1 mon counts, seeking to recover for certain engineering services claimed to have been rendered the City of Kis- simmee, during the latter stages of the real estate "boom," under an alleged contract between plaintiffs and the City. The first amended count, on the contract, alleged the execution of the contract between plaintiffs and defend- ant on December 2, 1925, and set forth the terms of the contract in haec verba. It also alleged [ * * *2] that in pursuance of said contract and employment plaintiffs did all work and performed all things, at the time and in the manner required; and that they filed with the City at the time and in the manner provided the estimated cost of the paving, which estimate was received by the City. The streets included in the paving project were then listed together with the width of each and the estimated cost. Then followed separate lists of streets on which (1) ex- tensions of water mains, (2) sanitary sewers, (3) house laterals and (4) street sewer improvements were alleged to have been made, together with allegations relating to the performance of all duties in regard thereto under the contract. The count alleged the amount due plaintiffs as follows: [*109] "Total estimated cost of project $823,972.50 Total estimated cost less Engineering Serv- ices $792,281.25 at 1 1/2% 11,884.22 To professional and engineerning services ren- dered account storm sewers, water mains, sanitary sewers, as per contract 18,629.70 Total $ 30,514.52 Packet Page -344- 10/28/2014 10.B. Page 2 139 Fla. 107, *; 190 So. 474, * *; 1939 Fla. LEXIS 1631, * ** Less credit of $18,616.56 Less credit of $1,000.00 Balance due $10,897.96." To the common counts defendant pleaded [ * * *3] "never was indebted as alleged," and placed itself upon the country. To the amended first count defendant pleaded (1) never promised as alleged, (2) payment, (3) that plaintiffs did not perform any services under the contract sued upon and (4) that plaintiffs did not do any work for defendant under said contract. Issue was joined on these four pleas. After taking writ of error to the Supreme Court, and having the ruling of the trial court, refusing to admit the contract in evidence, reversed, see Ramsey v. City of Kissimmee, I l l Fla. 387, 149 So. 553, a new trial was had. On the second trial, at the conclusion of plaintiffs' evidence, defendant made a motion to require plaintiffs to elect whether they were suing under the amended first count or under the common counts: and a motion for a directed verdict in favor of defendant. In denying both motions, [* *476] the court said, in effect, that even though he was denying both motions at that time, he would probably grant a directed verdict for the defendant on the first amended count at the close of all the testi- mony. A recess was then taken, after which Mr. Garrett announced that defendant rested without introducing any evidence, [ * * *4] and renewed his motion for a di- rected verdict in favor of defendant. After the court stated that it would have to grant the motion for a [*110] directed verdict as to the first amended count, Mr. Dickinson withdrew the common counts from con- sideration of the jury, and then took a voluntary non -suit as to the first amended count. Thereafter, the court entered its judgment of non -suit, reciting the substance of all of these proceed- ings and containing among other things, the following: "Whereupon the plaintiffs, by their attorneys, elected to stand and submitted to go on trial upon their amended first count of the declaration and withdrew from consid- eration of the jury the common counts, and thereupon the defendant renewed its motion for a directed verdict in its behalf on the amended first count of plaintiffs declara- tion, and the court did then and there upon consideration announce that he would grant said motion to direct a verdict for the defendant upon said amended first count of plaintiffs declaration to which ruling the plaintiffs did then and there except and did thereupon, before retire- ment of the jury, move the Court for a non -suit with bill of exceptions which said [ * * *5] motion the court did then and there grant." From this final judgment writ of error was taken. Since plaintiffs withdrew the common counts from consideration of the jury before taking their non -suit, the only count remaining was the first amended count on the contract, on which the court announced it would direct a verdict for the defendant. The result of this procedure in the trial court limits the question for review here as to whether or not the trial court, in announcing that he would direct a verdict for the defendant on the first amended count of the declara- tion, committed reversible error. The condition of the transcript of testimony included in this record is such that the case could have been sum- marily dismissed, as being in violation of the Rules of this Court, [*I I I ] because it is typed on a very thin, translucent quality of paper, and in addition to that is apparently a third or fourth carbon copy of the transcript. However, in order to avoid further delay in the disposi- tion of this litigation which has been in the courts of this State for over eleven years and to save additional costs to the parties, we have taken the time and patience to read this record, [ * * *6] including the improperly prepared transcript of the testimony, and give our considered judgment to this case though we do not by so doing in- tend that it shall induce other attorneys to violate the Rules of this Court in subsequent cases brought here. Under the plea of "did not promise as alleged," plaintiffs had the burden of proving due execution of the contract, and we believe their evidence in this regard was deficient. The charter of the City of Kissimmee provided that the City Commission shall make all contracts involving the expenditure of more than $300.00, and further pro- vided that "the action of the City Commission shall be expressed by ordinance or resolution and a record of the same shall be kept." This Special Charter of the City of Kissimmee was ratified, validated and confirmed by Chapter 9808, Special Acts of 1923. See Ramsey v. City of Kissimmee, 1 I I Fla. 387,149 So. 553. When this case was before us in Ramsey v. City of Kissimmee, 111 Fla. 387, 149 So. 553, we denominated the action of the City Commission of October 6, 1925, authorizing the entry into the contract with Ramsey Hemdon & Co. as a resolve, meaning a resolution, and the city charter was Packet Page -345- 139 Fla. 107, *; 190 So. 474, * *; 1939 Fla. LEXIS 1631, * ** satisfied [ * * *7] so far as authorizing the entry into a contract with Ramsey Herndon & Co. was concerned. The contract as drawn by Ramsey Herndon & Co. was presented to the City Commission at the meeting of December 2, 1925, for approval. The record before us fails to show that there was any motion, resolution or ordinance [*112] adopted approving the contract or putting it into effect. The charter provisions requiring the making of contracts involving this amount of money to be evidenced by resolution or ordinance were not complied with in this instance. The testimony of plain- tiffs' witnesses, which is the only testimony in the record, shows that at the meeting of the City Commission on December 2, 1925, after the proposed contract was read in [* *477] open meeting, Mr. Katz, one of the Com- missioners, said to Mr. Johnston, Mayor- Commissioner, to go ahead and sign the contract. No vote was taken on the question so far as this record shows. Mr. Johnston signed the contract as Mayor- Commissioner and turned it over to Mr. Steed, the City Attorney, and told him "to examine the contract that he had just signed as to its le- gality and if he found it all right, to submit it to" Ram- sey- Herndon [ * * *8] & Co. for their signatures. Mr. Steed made some changes in paragraph 4 of the contract, which changes were made in the form of a rider as well as by making some marks on the original paragraph 4. The contract with rider enclosed were the mailed to Ramsey Herndon & Co., and A. B. Herndon signed it for Ramsey Herndon & Co. The rider, which changed par- agraph 4 of the contract, was never submitted to the City Commission for its approval or disapproval, and was never passed on or adopted by the City Commission in any manner. Such altered paragraph 4 should have been approved and adopted by the City Commission in the same manner required by the charter for making a con- tract involving this amount of money. Even assuming for the purpose of illustration here that the Mayor- Commissioner had authority to bind the City by his signature, the contract signed by him was not the contract signed by A. B. Herndon for Ramsey Herndon & Co., and consequently there was no execution by the parties of the contract relied on for recovery. [ *113] It is contended that the payment of $1,000.00 on the contract ratified it. This is not sound because the contract must be ratified by the City Com- mission [ * * *9] in the same manner (by resolution or ordinance) in which it might have been originally adopted. The mere issuance of a warrant on motion of the City Commission is not such a ratification of the contract as will, under the provisions of the Clarter, bind the City of Kissimmee. See 3 McQuillan on Municipal Corporations (2d. ed.) pp. 970 -971, Sec. 1360, and cases there cited. 10/28/2014 10. B. Page 3 Persons contracting with a municipality must, at their peril, inquire into the power of the municipality, and of its officers, to make the contract contemplated. See Brown v. City of St. Petersburg, 111 Fla. 718, 153 So. 141; Lassiter v. Taylor, 99 Fla. 819, 128 So. 14, 69 A.L.R. 689. When this case was before us in Ramsey v. City of Kissimmee, 111 Fla. 387, 149 So. 553, we said: "Under the charter, the City of Kissimmee was, by its City Commission alone, authorized to make a contract of the kind sued on in this case. And the plaintiffs, in dealing with the City of Kissimmee, and in accepting a paper signed by the Mayor - Commissioner alone, were bound to ascertain the nature and extent of the Authority of the Mayor- Commissioner to sign the contract sued on, in behalf of the City. Town of Madison [ * * *10] v. Newsome (39 Fla. 149, 22 So. 270), supra. If in the first instance there was no such authority given to the Mayor - Commissioner to sign, or if the contract original- ly unauthorized, but nevertheless signed, has never been ratified by the City Commission so as to bind the City, plaintiffs cannot recover, and the jury should be so in- structed." We find from an examination of the record, that proof of the authority of the Mayor - Commissioner to sign the contract and thereby bind the City is not shown, even [* 114] assuming for the moment that the City Charter gave the power to the Mayor - Commissioner alone to sign contracts in behalf of the City, because the City Commission did not, so far as this record shows, take any vote on adoption of the contract when presented to the City Commission in open meeting on December 2, 1925. Neither is there any showing of any formal rati- fication of the act of signing the contract by the Mayor- Commissioner in the manner required by the City Charter. Applying the above quoted portion of the former decision in this case to the evidence adduced on the se- cond trial, there was nothing left for the trial judge to do except to direct a verdict in [ * * *11] favor of the de- fendant on the first amended count. The evidence showed that none of the paving was ever done because the bond market went down and the City could not realize enough from the sale of bonds at the prevailing prices to do all the work contemplated. The extension of an old contract with Southern Clay Manufacturing Co. to do the paving work under consid- eration was ordered by the City Commission on the same date that plaintiffs were ordered by resolve to be em- ployed as engineers, so plaintiffs' estimates of costs could not have been of any assistance [* *478] to Southern Clay Manufacturing Co. in putting in its bid for the work. Many of the streets selected to be paved were not selected in a lawful manner. Some were selected at Packet Page -346- 139 Fla. 107, *; 190 So. 474, * *; 1939 Fla. LEXIS 1631, * ** one time and some at another by City Commissioners individually, by civic organizations, or by interested groups and plaintiffs notified of the designated streets to be added to the original list. Plaintiffs did work under this purported contract on sanitory sewers, storm sewers and water main extensions, for which they were paid $18,616.56. Much of the engineering work done on the sewer and water main projects could be used on the pav- ing [ * * *12] projects and plaintiffs could employ the data for [ *] 151 which they had been paid on the pav- ing project without doing additional work. A. B. Hern- don, one of the plaintiffs, testified that there was no way 10/28/2014 10. B. Page 4 the work done on the sewers and water mains could be separated from the work done on the paving, so as to ascertain the amount of work actually done on the paving exclusive of all other work. The remedy of plaintiffs, if any they have, is on quantum meruit, and not on the contract, and direction of a verdict for the defendant on the count based on the contract would have been proper. Therefore the judg- ment of non -suit is affirmed. Affirmed. Packet Page -347- 10/28/2014 10.B. WOODWARD, PIRES, & LOMBARDO, P.A. ATTORNEYS AT LAW August 28, 2014 TO: Dwight E. Brock, Clerk of the Circuit Court (Clerk) FROM: Anthony P. Pires, Jr. RE: A. Ability of the Clerk to lawfully: I. make payments under contracts entered into by the County Administrator ( "Administrator ") or his designee(s) without the prior vote or approval of the Board of County Commissioners of Collier County ( "Board "); 2. make payments under contracts entered into by the Administrator or his designee(s) without a Board determination of the existence of a valid public purpose; and, B. Ability of the Board to: 1. delegate spending authority to the Administrator or his designee(s); 2. Establish contract thresholds for the Administrator or his designee(s) to execute contracts without either Board approval, Board vote or a Board determination of public purpose. You have asked for my legal opinion as to: 1. the ability of the Board to delegate discretionary spending authority to the Collier County Administrator ( "Administrator ") or his designee(s) (which designees include any and all County employees under the Administrator, regardless of position or title, collectively, "Designees "); 2. the ability of the Board to delegate to the Administrator or his Designees the Board's decision making authority to enter into binding contracts or agreements; 3. the ability of the Board to create contract thresholds, i.e. contracts of a value of less than $50,000, and delegate to the Administrator or his Designees the Board's power to execute such contracts without Board approval, Board vote or a Board determination of public purpose; 4, the validity of contracts entered into by the Administrator or his Designees without the approval or vote of the Board or a Board determination of public purpose; and, 5. the legality of payments by the Clerk under such contracts, i.e. the ability of the Clerk to make payments on contracts where the Board has neither approved nor voted on the contract nor made a determination of valid public purpose. In preparing and rendering my opinion, I have reviewed the request for a formal Attorney General's opinion to which this Memorandum is attached, the documents and materials referenced therein and other documents and materials germane to this Memorandum and request. This Memorandum incorporates in toto the contents of the request for a formal Attorney General's opinion to which this Memorandum is attached. THE CLERK The Clerk of the Circuit Court of Collier County, Florida, is the ex officio clerk of the board of county commissioners, auditor, recorder and custodian of all county funds. See Article VIII, section 1(d) of the Florida Constitution; Section 28.12, F.S. (2013). Collier County does not operate under a county charter and is a non - charter county under Article VIII, Section 1(f), Florida Constitution. The Clerk by law possesses certain pre -audit and post payment review functions and powers that requires the Clerk to refuse to make expenditures or authorize disbursement of public funds that are illegal, and if there is any question as to the legality of payment, the Clerk can not make such payment. Alachua County vs. Powers, 351 So.2d 32 (Fla. 1977); Brock v. Board of County Commissioners of Collier County, 21 So.3d 844 (Fla. 2ND DCA 2004; Mayes - 1 - Packet Page -348- 10/28/2014 10. B. Printing Company vs. Flowers, 154 So.2d 859, (Fla. 1st DCA 1963); and W and F Limited vs. Dunkie, 444 So.2d 554 (Fla. 4"' DCA 1984). Checks or warrants drawn on county accounts are issued and "attested by the clerk." Section 136.06(1), F.S. (2013). As stated in Alachua County vs. Powers: "The clerk, as auditor, is required by law to refuse to sign and deliver a county warrant for an unlawful expenditure, even though approved by the board of county commissioners." Pursuant to the provisions of Section 129.09, F.S. (2013) if the Clerk of Courts, acting as county auditor, signs any warrant to pay any illegal charge against the County or to pay any claim against the County not authorized by law, or County ordinance, the Clerk shall be personally liable for such amount, and if the Clerk signs the warrant willfully and knowingly, the Clerk is guilty of a second degree misdemeanor. Thus the Clerk is both civilly and criminally liable for any improper payment. THE BOARD The Board is the governing body of Collier County. Collier County is a non - charter county. Section 125.01, F.S. outlines various powers and duties of the Board as the governing body of Collier County. In that light, section 125.01(3)(a), F.S. provides, as to the powers of the Board, that: "(3)(a) The enumeration of powers herein shall not be deemed exclusive or restrictive, but shall be deemed to incorporate all implied powers necessary or incident to carrying out such powers enumerated, including, specifically, authority to employ personnel, expend funds, enter into contractual obligations, and purchase or lease and sell or exchange real or personal property." THE ADMINISTRATOR Part III of Chapter 125, F.S. is the "County Administration Law of 1974. Section 125.74(1)' F.S. outlines the powers and duties of the Administrator. In pertinent part, Section 125.74(1)(m) F.S provides: "125.74 County administrator; powers and duties.— (1) The administrator may be responsible for the administration of all departments responsible to the board of county commissioners and for the proper administration of all affairs under the jurisdiction of the board. To that end, the administrator may, by way of enumeration and not by way of limitation, have the following specific powers and duties to: (m) Negotiate leases, contracts, and other agreements, including consultant services, for the county, subject to approval of the board, and make recommendations concerning the nature and location of county improvements." In addition, Section 125.74(2), F.S. clearly states that none of the governmental power of the Board as the governing body is delegated to the Administrator: "(2) It is the intent of the Legislature to grant to the county administrator only those powers and duties which are administrative or ministerial in nature and not to delegate any governmental power imbued in the board of county commissioners as the governing body of the county pursuant to s. 1(e), Art. VII I of the State Constitution. To that end, the Section 125.74, F.S. will be referred to as the "Administrator's Statute ". -2- Packet Page -349- 10/28/2014 10.B. above specifically enumerated powers are to be construed as administrative in nature, and in any exercise of governmental power the administrator shall only be performing the duty of advising the board of county commissioners in its role as the policy- setting governing body of the county" Consistent with the language in Section 125.74(1)(m), F.S., the Board adopted its Ordinance No. 2013 -40, the "Collier County Administrator's Ordinance" (the "Administrator's Ordinance "). A copy of the Administrator's Ordinance is attached as Exhibit "A ". In line with the limitations in Part III of Chapter 125, F.S., the Administrator's Ordinance granted to the Administrator only those powers and duties which are administrative or ministerial in nature and does not delegate to the Administrator any governmental power imbued in the board of county commissioners as the governing body of the county pursuant to the Florida Constitution. Section 3 of the Administrator's Ordinance provides: "To this end, the below specifically enumerated powers are to be construed as administrative in nature, and in any exercise of governmental power the County Administrator shall only be performing the duty of advising the Board of County Commissioners in its role as the policy- setting governing body of the county and carrying out its directives and policies." THE PURCHASING ORDINANCE In 2013 the Board, in the context of the County's purchase or procurement of goods or services, consistent with both the powers of the Board outlined in Section 125.01, F.S. and the limitations on the Administrator contained in both Section 125.74(1)(m), F.S. and the Administrator's Ordinance, adopted Ordinance No. 2013 -69 as a substantially revised "Purchasing Ordinance (the "Purchasing Ordinance "). See attached Exhibit "B "). In pertinent part, the Purchasing Ordinance provides: A. the Purchasing Director has the authority to negotiate all purchases for all County agencies except as required by State, Federal or Local Law. (Section 5, Purchasing Ordinance). B. in keeping with Ch. 125, F.S., the Purchasing Ordinance grants to the Purchasing Director only those powers and duties which are ministerial in nature and does not delegate any governmental power imbued in the Board of County Commissioners as the governing body of the County pursuant to Fla. Const. Art. VIII, § 1(e) and to this end, the specifically enumerated powers are to be construed as ministerial in nature, for the purpose of carrying out the Board's directives and policies. (Section 5, Purchasing Ordinance). C. the Board shall, prior to payment, approve all expenditures with a finding that such expenditures serve a valid public purpose. (Section 7, Purchasing Ordinance). D. all contracts for commodities and services shall be authorized by the Board of County Commissioners. (Section 19.F, Purchasing Ordinance). E. the Purchasing Department may prepare and recommend a Purchasing Manual for adoption by the Board. (Section 6.4, Purchasing Ordinance). -3- Packet Page -350- 10/28/2014 10. B. THE PURCHASING MANUAL However, notwithstanding the clear language in the Administrator's Statute, the Administrator's Ordinance and the Purchasing Ordinance, the Administrator and Purchasing Department have prepared a Purchasing Manual that delegates, vests and grants to the Administrator and Purchasing Director blanket power to: A. execute contracts on behalf of the Board; and, B. enter into binding contracts on behalf of the Board;, without any prior review, action or approval of the Board. A copy of the proposed Purchasing Manual is attached as Exhibit "C ". The proposed Purchasing Manual also provides that purchases less than $50,000 may be entered into by the Purchasing Director, as the designee of the Administrator, without any review or approval of the Board and without a Board determination of the existence of a valid public purpose. As an example: 8:5 Non - Standard Agreements For purchases under $50,000, and for vendors who require a signed non - standard agreement, memorandum of understanding, contract, etc. the Purchasing Staff will complete negotiations with the vendor and forward to the County Attorney for final review and approval. The Purchasing Director shall execute the agreement on behalf of the Board of County Commissioners, and report the purchase pursuant to Section Seven. Purchases in General.' An approved non - standard agreement may be approved by the Purchasing Director as long as the cumulative annual expenses are less than $50,000. CONTRACTS AND AGREEMENTS EXECUTED BY THE ADMINISTRATOR /OTHER COUNTY PERSONNEL The Administrator and several other County personnel in the Administrator's agency have signed contracts and agreements on behalf of the County even though the contracts or agreements were not reviewed by or approved by the Board and even though the Board did not make a determination that the subject of the contracts served a valid public purpose. Some examples of these contracts and agreements are attached as Exhibit "D ". In addition to the issue as to the validity of such contracts per se, as raised in this request, some of the contracts or agreements may suffer from other legal infirmities. 3 In addition, on several occasions after the Board has reviewed and approved the specific terms and conditions of a contract, County staff have modified substantive terms and provisions without obtaining Board approval of the amended provisions. l It is important to note however that the stated "Procedures" under the referenced Section Seven appear to be an undisguised effort to evade the Board making the requisite findings and to improperly delegate the public purpose determination to the Clerk. 3 Examples of these are referenced and included in the request for the formal opinion. -4- Packet Page -351- 10/28/2014 10.B. ANALYSIS The Board, by Section 125.01(3)(a), F.S., has been granted the power and authority to expend funds and enter into contractual obligations. 'When the Legislature has prescribed the mode, that mode must be observed. When the controlling law directs how a thing shall be done that is, in effect, a prohibition against its being done in any other way ". See Alsop v. Pierce, 19 So. 2d 799, 805 -806 (Fla. 1944); Thayer v. State, 335 So. 2d 815, 817 (Fla. 1976). The applicable decisional law is that in the absence of statutory authority a public officer cannot delegate his /her powers even with the approval of the court. State v. Inter - American Center Authority, 84 So.2d 9 (Fla. 1955); Nicholas v. Wainwright, 152 So.2d 458 (Fla. 1963); Florida Dry Cleaning and Laundry Board v. Economy Cash & Cary Cleaners, Inc., 197 So. 550 (Fla. 1940); Wright v. Knight, 381 So. 2d 729 (Fla 31d DCA 1980); AGO's 073 -380, 074 -57, 074 -116, 075- 306 and 077 -31. See also AGO 2012 -31, footnote 12; Op. Att'y Gen. Fla. 88-61 (1988), (citing Op. Att'y Gen. Fla. 74 -116 (1974) and 67 C.J.S. Officers s. 194)). The Constitution does not contemplate that essential governmental powers or authority may be exercised by one not a duly commissioned officer. Florida Dry Cleaning and Laundry Board v. Economy Cash & Cary Cleaners, Inc., supra at page 872. Thus, it is very clear that absent specific statutory provisions, the Board may not delegate its powers or authority to the Administrator to make determinations that the expenditure of funds serves a county purpose or to enter into contracts which obligate the County: " "The county commission must make a determination that an expenditure serves a county purpose prior to the clerk of court issuing a warrant for payment." and "...the county commission may not delegate its governmental duty to make a determination that an expenditure serves a county purpose." [See Advisory Legal Opinion, AGO 2001 -29, April 23, 2001] Further: "It appears that the authority to execute contracts which obligate the county involve the exercise of independent discretion and judgment which may not be delegated absent statutory authority." and "In the absence of any statutory authority therefor, I am unable to conclude that the power to execute contracts on� behalf of the county commission may be delegated to a county administrator." [See Advisory Legal Opinion, AGO 88 -61, December 30, 1988 and also, Advisory Legal Opinion, AGO 74, April 10, 1974] From the foregoing it is clear that the Board alone has the authority to authorize payment of bills and to make the required determination that an expenditure serves a valid public purpose. -5- Packet Page -352- 10/28/2014 10.B. By the clear and unequivocal language of Section 125.74(2), F.S. the Florida Legislature has specifically provided that the Administrator's powers are limited to administrative or ministerial duties. As it relates to leases, contracts and other agreements, the Legislature has made it clear in Section 125.74(1)(m), F.S. that the Administrator is limited to negotiating leases, contracts and other agreements, "subject to the approval of the board ". Consistent with the statutory provisions, these limitations on the Administrator are contained in the Administrator's Ordinance and as to purchases, in the Purchasing Ordinance. Public policy requires that a governmental body's contracts must conform to the "strict letter of the law" to avoid corruption and waste of taxpayer money. See Walbum v. City of Naples 2005 WL 2322002, ( U.S. District Court, M.D. Florida, Sept. 22, 2005) Furthermore, one who contracts with a governmental body is bound to know the limitations of the governmental body's contracting authority. See Town of Indian River Shores v. Coll, 378 So.2d 53 (41' DCA 1980); Ramsey v. City of Kissimmee, 139 Fla. 107, 190 So. 474 (Fla. 1939) I have not found nor has anyone brought to my attention any statutory authority which would allow the Administrator to be delegated the Board's discretionary powers to contract and obligate the County or to make the determination that an expenditure of funds serves a county or public purpose. Similar to the situation in Frankenmuth Mutual Insurance Company vs. Magaha, 769 So.2d 1012 (Fla. 2000), by the enactment of Section 125.74(1)(m) and(2), F.S., the Legislature clearly established that contracts may not be entered into and expenditures may not be made without approval of the Board. As in Frankenmuth, the Administrator has no independent authority to enter into any contracts and bind the Board. Several Florida courts have determined that "Agreements entered into by public bodies which fail to comply with statutory requirements are void ". Palm Beach County Health Care Dist. v. Everglades Meml Hosp., Inc., 658 So.2d 577, 581 (Fla. 4th DCA 1995) (lease agreement involving a public hospital was void because it was contrary to Florida Statute 155.40); City of Hollywood v. Witt, 789 So.2d 1130, 1132 (Fla. 4th DCA 2001) (same); Town of Indian River Shores v. Coll, 378 So.2d 53, 55 (Fla. 4th DCA 1979) (Court refused to enforce an employment contract between the mayor and an individual because an ordinance required that the type of contract at issue be authorized by the entire town council). However, under Frankenmuth, the Board does have the ability to ratify and approve a contract that was initially an unauthorized agreement and outlined the necessary steps that must be taken. Approval may take the form of a formal resolution by the Board. If not made by formal resolution, approval by the Board: 1. must be made in compliance with Florida's Sunshine Law, in the same manner that a formal approval would have required; and, 2. the Board must be fully informed and have full knowledge of all material facts and circumstances relating to the unauthorized act or transaction. The courts apply a three -prong test for determining whether an after - the -fact "approval," or ratification, has occurred: 1. The Board must have the power to approve the agreement. 2. The Board must ratify an agreement in the same manner in which the agreement would have been initially approved. For example, the approval must be made in accordance with the "Sunshine Law." Additionally, where a law or an ordinance requires the Board to take !Q Packet Page -353- 10/28/2014 10.B. action in a specified manner, such as by passing a formal resolution then an after - the -fact approval must satisfy the specified manner to be valid. 3. Finally, in ratifying the agreement in the same manner in which it initially could have been approved, the Board must have full knowledge of the material facts relative to the agreement. CONCLUSION Therefore, based upon the foregoing, it is my opinion until judicially or administratively determined to the contrary: 1. the Board of County Commissioners of Collier County, Florida may not delegate its discretionary spending authority to the Administrator or his Designees. 2. the Board of County Commissioners of Collier County, Florida may not delegate its discretionary decision - making authority to the Administrator or his Designees. 3. the Board of County Commissioners of Collier County, Florida may not establish contract thresholds for the Administrator or his Designees to execute contracts without Board approval or vote or a Board determination of the existence of a valid public purpose; i.e., the Administrator or his Designees do not and cannot possess the authority or power to enter into any binding contracts, much less than contracts of a value less than $50,000 4. any contracts entered into by the Administrator or his Designees without either Board approval or vote, i.e., a Board determination of the existence of a valid public purpose, are not valid contracts. 5. the Board does have the ability to ratify and approve a contract that was initially an unauthorized agreement, provided that the three -prong test outlined in Frankenmuth has been satisfied. 6. the board can enter into "master contracts" or project contracts and thereby determine the public purpose of the expenditure of public funds and thereafter authorize purchases through project budgeting or budget line items (such as office supplies contracts and budgeting for office supplies), whereupon expenditures can then be made without further board action. 7. the Clerk may not lawfully make payments to persons under contracts entered into by the Administrator or his Designees without Board approval or vote and a Board determination of the existence of a valid public purpose. 8. approval by the Board of a summary "disbursement list' pursuant to F. S. 136.06(1) does not validate agreements or contracts which have not been reviewed and approved by the Board. (See Ramsey v. City, of Kissimmee, 139 Fla. 107, 190 So. 474 (Fla. 1939), Frankenmuth Mutual Insurance Company vs. Magaha, 769 So.2d 1012 (Fla. 2000) 7- Packet Page -354-