The Florida Senate
BILL ANALYSIS AND FISCAL IMPACT STATEMENT
(This document is based on the provisions contained in the legislation as of the latest date listed below.)
Prepared By: The Professional Staff of the Committee on Criminal Justice
BILL: CS/SB 1664
INTRODUCER: Judiciary Committee and Senators Perry and Boyd
SUBJECT: Unlawful Assemblies
DATE: February 7, 2022
ANALYST STAFF DIRECTOR REFERENCE ACTION
1. Ravelo Cibula JU Fav/CS
2. Erickson Jones CJ Pre-meeting
3. RC
Please see Section IX. for Additional Information:
COMMITTEE SUBSTITUTE - Substantial Changes
I. Summary:
CS/SB 1664 addresses unlawful assemblies that specifically target residences to harass or disturb
people inside their homes.
Specifically, the bill amends the unlawful assembly statute to expressly prohibit a person from
picketing or protesting before or about another person’s home in order to harass or disturb the
person in his or her home. A person who engages in the prohibited conduct commits a second
degree misdemeanor.
The bill may have a jail bed impact but this impact is indeterminate. See Section V. Fiscal
Impact Statement.
The bill takes effect October 1, 2022.
II. Present Situation:
Frisby v. Shultz: The First Amendment and Restrictions on Targeted Residential Picketing
or Protesting
The First Amendment of the U.S. Constitution guarantees that “Congress shall make no law ...
abridging the freedom of speech, or of the press; or the right of the people peaceably to
REVISED: BILL: CS/SB 1664 Page 2
assemble, and to petition the Government for a redress of grievances.”
1
The rights guaranteed by
the First Amendment apply with equal force to state governments through the due process clause
of the Fourteenth Amendment.
2
“Despite the seemingly clear imperative of the text of the First
Amendment, the Supreme Court has held that a content-neutral restriction of speech is
constitutional if it ‘serves a significant government interest,’ ‘is narrowly tailored’ to achieving
those ends, and leaves ample alternative avenues for speech.”
3
The “principal inquiry in determining whether a restriction on speech is content-neutral is
‘whether the government has adopted a restriction on speech because of the message it conveys.
The government’s purpose is the controlling consideration.’”
4
“[T]he government may impose reasonable restrictions on the time, place and manner of
protected speech[.]”
5
“[T]he requirement of narrow tailoring is satisfied ‘so long as the ...
regulation promotes a substantial governmental interest’”
6
and “the means chosen are not
substantially broader than necessary to achieve the government’s interest.”
7
In Frisby v. Schultz,
8
the U.S. Supreme Court upheld an ordinance enacted in Brookfield,
Wisconsin. This ordinance banned targeted residential picketing. The precise language of the
ordinance was described as follows: “It is unlawful for any person to engage in picketing before
or about the residence or dwelling of any individual in the Town of Brookfield.”
9
The Court
stated that the appellees and others engaged in picketing “on a public street outside the
Brookfield residence of a doctor who apparently performs abortions at two clinics in neighboring
towns.”
10
The Court described the picketing as:
generally orderly and peaceful; the town never had occasion to invoke any of its various
ordinances prohibiting obstruction of the streets, loud and unnecessary noises, or
disorderly conduct. Nonetheless, the picketing generated substantial controversy and
numerous complaints.
11
In undertaking its analysis of the ordinance, the Court first identified the ordinance as impacting
protected speech.
12
Next, the Court noted that in ascertaining “what limits, if any, may be placed
on protected speech, we have often focused on the ‘place’ of that speech, considering the nature
of the forum the speaker seeks to employ. Our cases have recognized that the standards by which
1
Amend. I, U.S. Const.
2
Amend. XIV, U.S. Const. See also Art. I, Fla. Const.
3
Bell v. Winter Park, Fla., 745 F.3d 1318, 1322 (11th Cir. 2014) (footnotes omitted), citing Frisby v. Schultz, 487 U.S. 474,
484-485 (1988). The Eleventh Circuit court noted that this is an intermediate scrutiny test rather than the strict scrutiny test
applied to content-based restrictions on speech. Id. at 1322, n. 7, citing and quoting CAMP Legal Def. Fund, Inc. v. City of
Atlanta, 451 F.3d 1257, 180 (11th Cir. 2006).
4
Id. at 1333, n. 6, citing and quoting Ward v. Rock Against Racism, 491 U.S. 781, 791 (1989) (citation omitted).
5
Ward, supra, 491 U.S. at 791. “Even protected speech is not equally permissible in all places and at all times.” Cornelius v.
NAACP Legal Defense & Educational Fund, Inc. 473 U.S. 788, 799 (1985).
6
Id. at 799, citing and quoting United State v. Albertini, 472 U.S. 675, 689 (1985) (other citation omitted).
7
Id. at 800.
8
487 U.S. 474 (1988).
9
Id. at 477 (citing appellate record).
10
Id. at 476.
11
Id.
12
Id. at 479. BILL: CS/SB 1664 Page 3
limitations on speech must be evaluated ‘differ depending on the character of the property at
issue.’”
13
The Court determined that public streets and sidewalks were impacted by the
ordinance, and that they were public fora and “must be judged against the stringent standards we
have established for restrictions on speech in traditional public fora[.]”
14
Those “standards” are
provided in the content-neutral analysis previously described.
The Court accepted the lower federal court’s conclusion that the ordinance was content-neutral.
15
While the next step in the analysis is typically to determine whether the regulation is narrowly
tailored to serve a governmental interest, the court elected to first address whether the ordinance
left open ample alternative channels of communication because this question was “easily
answered.”
16
The Court determined that the ordinance was “readily subject to a narrowing
construction that avoids constitutional difficulties.” The ordinance only prohibited “focused
picketing taking place solely in front of a particular residence[.]”
17
The ordinance did not bar
protestors from residential neighborhoods, including marching through those neighborhoods or
walking a route in front of houses in those neighborhoods.
18
The Court then inquired whether the ordinance served a significant government interest. The
court relied on its precedent to answer the question affirmatively. This precedent identified “[t]he
state’s interest in protecting the well-being, tranquility, and privacy of the home” as being
“certainly of the highest order in a free and civilized society.”
19
The Court also noted:
One important aspect of residential privacy is protection of the unwilling listener.
Although in many locations, we expect individuals simply to avoid speech they do not
want to hear, ... the home is different. “That we are often ‘captives' outside the sanctuary
of the home and subject to objectionable speech ... does not mean we must be captives
everywhere.” Rowan v. Post Office Dept., [397 U.S. 728, 738 (1970)]. Instead, a special
benefit of the privacy all citizens enjoy within their own walls, which the State may
legislate to protect, is an ability to avoid intrusions. Thus, we have repeatedly held that
individuals are not required to welcome unwanted speech into their own homes and that
the government may protect this freedom....
20
Finally, the Court inquired whether the ordinance was narrowly tailored to serve the identified
government interest. The Court stated that “[a] statute is narrowly tailored if it targets and
eliminates no more than the exact source of the ‘evil’ it seeks to remedy.”
21
Further, a complete
ban “can be narrowly tailored, but only if each activity within the proscription’s scope is an
appropriately targeted evil.”
22
The Court found that the “type of focused picketing prohibited” by
the ordinance was “fundamentally different from more generally directed means of
13
Id., citing and quoting Perry Education Assn. v. Perry Local Educators’ Assn., 460 U.S. 37, 44 (1983).
14
Id. at 480-481.
15
Id. at 482.
16
Id.
17
Id. at 482-483 (relying on representations from counsel at oral argument).
18
Id. at 483 (relying on representations from counsel at oral argument).
19
Id. at 484, citing and quoting Carey v. Brown, 447 U.S. 455, 471 (1980).
20
Id. at 484-485 (other citations omitted).
21
Id. at 485 (citation omitted).
22
Id. BILL: CS/SB 1664 Page 4
communication that may not be completely banned in residential areas,” citing its decisions
regarding handbilling and solicitation.
23
The Court further found:
... the picketing is narrowly directed at the household, not the public. The type of
picketers banned by the Brookfield ordinance generally do not seek to disseminate a
message to the general public, but to intrude upon the targeted resident, and to do so in an
especially offensive way. Moreover, even if some such picketers have a broader
communicative purpose, their activity nonetheless inherently and offensively intrudes on
residential privacy....
24
The Court opined that the “First Amendment permits the government to prohibit offensive
speech as intrusive when the ‘captive’ audience cannot avoid the objectionable speech.”
25
The
Court concluded that the ordinance was narrowly tailored to addresses targeted picketing of
residents who were essentially “captives” to this picketing.
The target of the focused picketing banned by the Brookfield ordinance is just such a
“captive.” The resident is figuratively, and perhaps literally, trapped within the home, and
because of the unique and subtle impact of such picketing is left with no ready means of
avoiding the unwanted speech.... Thus, the “evil” of targeted residential picketing, “the
very presence of an unwelcome visitor at the home,” [Carey v. Brown, 447 U.S. 455, 478
(1980) (Rehnquist, J., dissenting)], is “created by the medium of expression itself.” [City
Council of Los Angeles v. Taxpayers for Vincent, 466 U.S. 789, 810 (1984)].
Accordingly, the Brookfield ordinance’s complete ban of that particular medium of
expression is narrowly tailored.
26
Unlawful Assembly, Breach of Peace, and Disorderly Conduct
Although protests, at face value, are legal, certain offenses may occur at or near a protest that are
not protected under the First Amendment. For example, s. 870.02(1), F.S., provides that it is a
second degree misdemeanor
27
for three or more persons meeting together to commit a breach of
the peace
28
or any other unlawful act.
The Florida Supreme Court has held that the “basic common law elements apply” to s. 870.02,
F.S., and has construed this statute “to prohibit (1) an assembly of three or more persons who, (2)
having a common unlawful purpose, (3) assemble in such a manner as to give rational, firm, and
courageous persons in the neighborhood of the assembly a well-grounded fear of a breach of the
peace.”
29
The Court has further held that this statute does not infringe on free speech or assembly
if the term “unlawful assembly” used in s. 870.02, F.S., meets the Court’s previously-described
23
Id. at 486 (citations omitted).
24
Id.
25
Id. at 487 (citations omitted).
26
Id. at 487-488 (other citation omitted).
27
A second degree misdemeanor is punishable by up to 60 days in jail and a fine of up to $500. Sections 775.082 and
775.083, F.S.
28
Emphasis provided by staff.
29
State v. Simpson, 347 So.2d 414, 415 (Fla. 1977) (footnote omitted). BILL: CS/SB 1664 Page 5
definition, the elements are “established by the circumstances of the incident,” and the “charging
document … articulate[s] the facts which establish each of those elements.”
30
Section 877.03, F.S., provides that it is a second degree misdemeanor to commit such acts as are
of a nature to corrupt the public morals, or outrage the sense of public decency, or affect the
peace and quiet of persons who may witness them, or engage in brawling or fighting, or engage
in such conduct as to constitute a breach of the peace or disorderly conduct.
31
The unlawful assembly statute differs from the breach of peace or disorderly conduct statute by
requiring that a person arrested for unlawful assembly be held in custody until he or she is
brought before the court for admittance to bail in accordance with ch. 903, F.S.
32
Section 870.04, F.S., requires the following officers to go among persons who “unlawfully,
riotously, or tumultuously assemble in any county, city or municipality” (or as near to them as
may be done safely) and in the name of the state command these persons “immediately and
peaceably to disperse”:
The sheriff or the sheriff’s deputies;
The mayor;
Any commissioner, council member, alderman, or police officer of the city or municipality;
Any officer or member of the Florida Highway Patrol;
Any officer or agent of the Fish and Wildlife Conservation Commission or the Department of
Environmental Protection;
Any beverage enforcement agent;
Any personnel or representatives of the Department of Law Enforcement or its successor; or
Any other peace officer.
This requirement applies regardless of the number of assembled persons or whether they are
armed or not.
Section 870.04, F.S., also provides that if the assembled persons, after receiving the command to
disperse, do not immediately and peaceably disperse, the officers must command the assistance
of “all such persons in seizing, arresting, and securing such persons in custody.”
30
Id. at 416.
31
Emphasis provided by staff. The Florida Supreme Court has narrowed the application of the statute to avoid possible
infringement on constitutionally-protected speech, limiting its application so it only applies “to words which ‘by their very
utterance . . . inflict injury or tend to incite an immediate breach of the peace,’ White v. State, [330 So.2d 3, 7 (Fla.1976)]; See
Chaplinsky v. New Hampshire, [315 U.S. 568, 572 (1942)]; or to words, known to be false, reporting some physical hazard in
circumstances where such a report creates a clear and present danger of bodily harm to others.” State v. Saunders, 339 So.2d
641, 644 (Fla. 1976). The Court in Saunders construed s. 877.03, F.S., “so that no words except ‘fighting words’ or words
like shouts of ‘fire’ in a crowded theatre fall within its proscription, in order to avoid the constitutional problem of
overbreadth, and ‘the danger that a citizen will be punished as a criminal for exercising his right of free speech.’” Id. at 644,
quoting Spears v. State, 337 So.2d 977, 980 (Fla. 1976).
32
Section 870.02(2), F.S. BILL: CS/SB 1664 Page 6
Finally, s. 870.04, F.S., deems the following persons present at a riot or unlawful assembly to be
one of the rioters or persons unlawfully assembled who may be prosecuted and punished
accordingly:
A person who is commanded to aid and assist in seizing and securing a rioter or person
unlawfully assembled, or assist in suppressing a riot or unlawful assembly, but refuses or
neglects to obey this command; or
A person who is required by an officer to depart from a riot or unlawful assembly but refuses
and neglects to do so.
33
Recent Targeted Protests at Private Residences
Protests, especially for highly-publicized issues, have sometimes targeted specific individual’s
homes. Both Senators Marco Rubio and Rick Scott have had protests outside their private
residences.
34
There were protests outside the home of a public school board member in Brevard
County, Florida, over “LGBTQ-affirming” school district policies.
35
In Windermere, Florida,
groups stood outside of a home owned by Derek Chauvin who, at the time of the protest, had
been charged but not convicted for the murder of George Floyd.
36
Outside of Florida, the mayors
of Chicago and Portland have drawn protests to their private residences.
37,
38
III. Effect of Proposed Changes:
The bill creates a new criminal offense to picket or protest before or about the residence or
dwelling of any person with the intent to harass or disturb that person in his or her home. The bill
provides a definition of “dwelling” to include “any building, structure, or portion thereof which
is occupied as, or designed or intended for occupancy as, a residence by one or more families.” A
person who violates this section commits a second degree misdemeanor and may be sentenced to
up to 60 days in county jail and assessed a $500 fine.
33
In a case involving an earlier version of the statute, the Florida Supreme Court held that “[u]nder this statute the offense
can only be committed when the unlawful assembly has been ordered to disperse by those officers of the law named in the
statute. Lezama v. State, 110 Fla. 304307, 148 So. 304 (Fla. 1933).
34
Jacob Ogles, Protesters to convene on Marco Rubio’s, Rick Scott’s homes to demand challenge to Joe Biden win, Florida
Politics, Jan. 1, 2021, available at https://floridapolitics.com/archives/405357-protesters-to-convene-on-marco-rubios-rick-
scotts-homes-to-demand-challenge-to-joe-biden-win/ (last visited on Feb. 2, 2022); and Lautaro Grinspan, Trump supporters
gather in front of Marco Rubio’s West Miami home. ‘You work for us.’, The Spokesman Review, Jan. 3 2021 (originally
published in The Miami Herald), available at https://www.spokesman.com/stories/2021/jan/03/trump-supporters-gather-in-
front-of-marco-rubios-w/ (last visited on Feb. 2, 2022).
35
Bailey Gallion, Protesters' anti-LGBTQ sentiments met by messages of love outside BPS board member's home, Florida
Today, Apr. 9, 2021, available at https://www.floridatoday.com/story/news/education/2021/04/09/protest-outside-brevard-
school-board-member-home-spurs-message-love/7157736002/ (last visited on Feb. 2, 2022).
36
Protesters remain at Orlando-area home owned by officer connected to George Floyd’s death, May 30, 2020, Fox 35
(Orlando), available at https://www.fox35orlando.com/news/protesters-remain-at-orlando-area-home-owned-by-officer-
connected-to-george-floyds-death (last visited on Feb. 2, 2022). However, Chauvin was not in the home when the protest
occurred. Id.
37
Madeline Holcombe, Chicago protesters rally at mayor’s house a day after clashes with police, CNN, July 19, 2020,
available at https://www.cnn.com/2020/07/19/us/chicago-protest-lori-lightfoot/index.html (last visited on Feb. 2, 2022).
38
The Portland mayor actually planned to move out of his apartment due to the targeted protests at his home. Andrew Hay,
Portland mayor to leave home targeted by protestors, Reuters, Sept. 2, 2020, available at https://www.reuters.com/article/us-
global-race-usa-protests-portland/portland-mayor-to-leave-home-targeted-by-protesters-idUSKBN25T32R (last visited on
Feb. 2, 2022). BILL: CS/SB 1664 Page 7
Both the Brookfield ordinance on targeted residential picketing that was reviewed by the U.S.
Supreme Court in Frisby v. Shultz
39
and the offense created by the bill focus on targeted
picketing; specifically, they focus on picketing before or about the residence of any person.
40
However, there are also some differences between the Brookfield ordinance and the offense
created by the bill. The Brookfield ordinance mentions “picketing”; the offense created by the
bill mentions “picket or protest.” The Brookfield ordinance imposes a complete ban on targeted
picketing before or about a residence or dwelling; the offense created by the bill only punishes “a
picket or protest before or about the residence or dwelling of any person with the intent to harass
or disturb that person in his or her home.”
41
Also, unlike the Brookfield ordinance, the offense
created by the bill defines what a dwelling is.
The bill also specifically states that the purpose of the new offense is to “serve the states
significant interest in protecting the well-being, tranquility, and privacy of the home and
protecting residents from the detrimental effect of targeted picketing.” As previously noted, the
U.S. Supreme Court has identified “[t]he state’s interest in protecting the well-being, tranquility,
and privacy of the home” as being “certainly of the highest order in a free and civilized
society.”
42
The bill takes effect October 1, 2022.
IV. Constitutional Issues:
A. Municipality/County Mandates Restrictions:
The bill does not appear to require cities and counties to expend funds or limit their
authority to raise revenue or receive state-shared revenues as specified by Article VII,
s. 18, of the Florida Constitution.
B. Public Records/Open Meetings Issues:
None.
C. Trust Funds Restrictions:
None.
D. State Tax or Fee Increases:
None.
39
See footnote 8, supra.
40
See text of the Brookfield ordinance in the “Present Situation” section of this analysis, supra.
41
Neither “harass” nor “disturb” is defined. See “Other Constitutional Issues” section of this analysis, infra.
42
Carey v. Brown, 447 U.S. 455, 471 (1980). BILL: CS/SB 1664 Page 8
E. Other Constitutional Issues
First Amendment
It’s important to note that Frisby v. Shultz
43
involved a First Amendment facial challenge
to the Brookfield ordinance. The U.S. Supreme Court’s decision did not bar First
Amendment challenges based on unconstitutional application of a law. For example, the
Court speculated that the Brookfield ordinance may not apply if the resident used his or
her home as a place of business or public meeting “since the ordinance’s goal is the
protection of residential privacy.”
44
Additionally, not every court has reached the same conclusion as the U.S. Supreme Court
in Frisby regarding a targeted residential picketing ordinance. For example, post-Frisby,
the federal Sixth Circuit Court of Appeals (Sixth Circuit) found that a targeted residential
picketing ordinance enacted in Upper Arlington, Ohio, was unconstitutionally
overbroad.
45
This ordinance was identical to the Brookfield ordinance reviewed in
Frisby.
46
Regarding the Brookfield ordinance and the Frisby holding on that ordinance,
the Sixth Circuit opined:
The ordinance construed by the Court in Frisby was unconstitutionally overbroad
as written but was saved by the extraordinary measure of accepting counsel’s
representation at oral argument before the Supreme Court as to how the ordinance
would be enforced. Although there is precedent for this approach, four Justices
were highly critical of saving the ordinance by this device. In his dissent, Justice
Stevens offered a simple and practical alternative: [I]t is a simple matter for the
town to amend its ordinance and to limit the ban to conduct that unreasonably
interferes with the privacy of the home and does not serve a reasonable
communicative purpose. [Frisby v. Shultz, 487 U.S. 474, 499 (1988)] (Stevens, J.,
dissenting).
47
The Sixth Circuit stated that, “[n]otwithstanding the procedure adopted in Frisby, we
know of nothing that requires us to accept representations from the City’s counsel”
regarding enforcement of the ordinance.
48
The Sixth Circuit was unclear regarding those
representations, and uncertain if counsel could bind either the legislative body of the City
or its police department.
49
The Sixth Circuit also believed “the record demonstrate[d] that
the City’s idea of what constitutes an enforcement procedure that does not offend the
Constitution” was in conflict with the Supreme Court’s post-Frisby holding in Madsen v.
Women’s Health Center,
50
which the Sixth Circuit claimed “makes it clear that any linear
43
See footnote 8, supra.
44
Id. at 488.
45
Vittitow v. City of Upper Arlington, 43 F.3d 1100 (6th Cir. 1995), cert. denied, 515 US 1121 (1995).
46
Id. at 1106.
47
Id.
48
Id.
49
Id.
50
114 S.Ct. 2516 (1994). BILL: CS/SB 1664 Page 9
extension beyond the area ‘solely in front of a particular residence’ is at best suspect, if
not prohibited outright.”
51
Vagueness
Criminal laws may not include “such vague and broad language that a person of common
intelligence must speculate about its meaning and be subjected to arrest and punishment
if the guess is wrong.”
52
A vague statute, “because of its imprecision, may also invite
arbitrary and discriminatory enforcement.”
53
However, the fact that the Legislature may not have defined words or chosen the clearest
or most precise language in a statute does not necessarily render a statute
unconstitutionally vague.
54
“In the absence of a statutory definition, resort may be had to
case law or related statutory provisions which define the term, and where a statute does
not specifically define words of common usage, such words are construed in their plain
and ordinary sense.”
55
The bill does not define “harass.” Some current offenses that use the term “harass” define
it; others do not. For example, s. 784.048, F.S., which punishes stalking, defines “harass”
as engaging in a course of conduct directed at a specific person which causes substantial
emotional distress to that person and serves no legitimate purpose.
56
In contrast,
s. 365.16, F.S., which punishes harassing phone calls, does not define “harass.”
It does not appear that the term “disturb” is defined in Florida law. An example of its use
(without definition) is s. 871.015, F.S., which punishes knowingly engaging in protest
activities or knowingly causing protest activities to occur within 500 feet of the property
line of a residence, cemetery, funeral home, house of worship, or other location during or
within 1 hour before or 1 hour after the conducting of a funeral or burial at that place.
“Protest activities” is defined in the statute as any action, including picketing, which is
undertaken with the intent to interrupt or disturb a funeral or burial.
57
51
Vittitow, supra, 43 F.3d at 1105 (footnote omitted), quoting Madsen, supra, 114 S.Ct. at 2530.
52
State v. Wershow, 343 So.2d 605, 608 (Fla.1977). If a law is “indefinite and susceptible of differing constructions, the rule
of lenity applies; the statute must be construed in the manner most favorable to the accused.” State v. Del Castillo, 890 So.2d
376, 398 (Fla. 3d DCA 2004). See s. 775.021(1), F.S. (codifying the rule of lenity).
53
Southeastern Fisheries Ass’n, Inc. v. Department of Natural Resources, 453 So.2d 1351, 1353 (Fla. 1984).
54
State v. Barnes, 686 So.2d 633, 637 (Fla. 2d DCA 1996), review denied, 695 So.2d 698 (Fla.1997), cert. denied, 522
U.S. 903 (1997). “[A] defendant who establishes only that the statute is vague in the sense that it requires a person to
conform his or her conduct to an imprecise but comprehensible standard cannot prevail on a vagueness challenge.” Id.
55
State v. Hagan, 387 So.2d 943, 945 (Fla.1980) (citations omitted). In Barnes, supra, the court determined that the
undefined terms “high speed vehicle pursuit” and “high speed,” which appeared in a statute punishing unlawful flight from a
law enforcement officer, were not impermissibly vague in all of their applications. The meaning of the term “high” could be
ascertained from a dictionary definition and the meaning of the term “high speed pursuit” could be ascertained from a plain
reading.
56
Section 784.048(1)(a), F.S.
57
Section s. 871.015(1)(c), F.S. (emphasis provided by staff). BILL: CS/SB 1664 Page 10
V. Fiscal Impact Statement:
A. Tax/Fee Issues:
None.
B. Private Sector Impact:
None.
C. Government Sector Impact:
The bill may have a jail bed impact but this impact is indeterminate.
VI. Technical Deficiencies:
None.
VII. Related Issues:
None.
VIII. Statutes Affected:
This bill substantially amends section 870.02 of the Florida Statutes.
IX. Additional Information:
A. Committee Substitute – Statement of Substantial Changes:
(Summarizing differences between the Committee Substitute and the prior version of the bill.)
CS by Judiciary on January 31, 2022
The CS provides a definition for “dwelling” as used in the bill to include “any building,
structure, or portion thereof which is occupied as, or designed or intended for occupancy
as, a residence by one or more families.”
B. Amendments:
None.
This Senate Bill Analysis does not reflect the intent or official position of the bill’s introducer or the Florida Senate.