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STARR v. SCHOOL DISTRICT OF PALM BEACH COUNTY PUBLIC SCHOOLS (2024)

District Court of Appeal of Florida, Third District.2024-05-15No. No. 3D23-1800

Authorities cited

No cited authorities resolved to law.co cases yet.

Opinion

Affirmed. See Perry v. Dept of Children & Families, 220 So. 3d 546, 549-50 (Fla. 3d DCA 2017) (noting that “when actions undertaken by a Florida administrative agency affect ones ‘substantial interests’, the affected person is entitled to an administrative hearing.”) See also Schs. Bd. of Palm Beach Cnty. v. Survivors Charter Schs., Inc., 3 So. 3d 1220, 1231 (Fla. 2009) (noting that a school board is an “agency” as defined in Chapter 120, Administrative Procedure Act, and that Chapter 120 applies generally to a school boards decision making); Herold v. Univ. of So. Fla., 806 So. 2d 638 (Fla. 2d DCA 2002) (professors substantial interests were not affected by Universitys decision to deny him a tenured professorship, noting “case law makes it clear that a substantial interest is one based on a legal entitlement, and not on a mere unilateral expectation”) (citing Fertally v. Miami-Dade Cmty. Coll., 651 So. 2d 1283 (Fla. 3d DCA 1995) (holding nonrenewal of professors annual contract did not affect her substantial interests for purposes of section 120.57)) (additional citations omitted); Jones v. Miami-Dade Cnty. Public Schs., 816 So. 2d 824 (Fla. 3d DCA 2002) (holding no substantial interest entitling school administrator to hearing where his annual contract was not renewed).

PER CURIAM.