Appeals Court Says Miramar Police Arbitration Hearing Need Not Be Open
Florida’s Fourth District Court of Appeal has reversed a ruling that would have required a labor-arbitration hearing involving the City of Miramar and the Miramar Police Department to be open to the public under the state Sunshine Law.
The appellate court issued its decision June 3, 2026, in case No. 4D2025-1311. It held that Florida Statutes section 286.011(1) does not require every arbitration between a public employer and a public-employee union to be open to the public.
The decision overturns a contrary declaratory judgment from the circuit court. The underlying case was numbered 062024CA014072AXXXCE.
How the dispute began
The legal dispute grew out of discipline imposed on Miramar police officer Leonardo Braga after an investigation by the police department found violations of department policies.
After the city denied a grievance related to that discipline, the Florida State Lodge Fraternal Order of Police filed a grievance under its collective bargaining agreement with Miramar. The union then demanded arbitration.
The parties disagreed over whether the arbitration hearing should be open to the public or conducted as a closed proceeding. That disagreement led to the court case over how Florida’s Sunshine Law applies to labor arbitration involving a public employer and a public-employee union.
Miramar and Police Chief Delrish Moss appealed the lower court’s judgment. The Fourth District concluded that the trial court had interpreted the statute too broadly when it required the arbitration hearing to be open.
What the ruling changes
The ruling gives Miramar and other Florida public employers more room to conduct labor-grievance arbitration hearings privately when the law does not otherwise require public access. It also narrows the circumstances in which section 286.011(1) alone requires such proceedings to be open.
The decision is limited to the public-access question presented in the appeal. It does not determine whether the discipline imposed on Braga was justified, nor does it say whether his grievance should succeed or fail.
It also does not establish that every future arbitration involving Miramar police officers will be closed. The court’s holding is that the Sunshine Law does not automatically require all arbitrations between public employers and public-employee unions to be open.
What happens next
The opinion states that the decision was not final pending the disposition of any timely motion for rehearing. The appellate ruling therefore resolves the lower court’s public-access judgment unless further proceedings alter that status.
For Miramar, the immediate significance is procedural: the city’s labor-arbitration hearing involving the police union is not required to be open solely because it is an arbitration between a public employer and a public-employee union. The appellate opinion, however, addresses neither the final outcome of Braga’s disciplinary grievance nor the merits of the underlying personnel dispute.
Sources
- The City of Miramar, Florida, et al. v. Florida State Lodge Fraternal Order of Police, Inc., et al., Florida Fourth District Court of Appeal
- The City of Miramar, Florida, et al. v. Florida State Lodge Fraternal Order of Police, Inc., et al., Justia, reproducing Florida Fourth District Court of Appeal decision
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