Florida/Georgia Personal Injury & Workers Compensation

...Chapter 98-223 contains 15 sections of which 13 are substantive.[n] Section 1 creates section 832.09, Florida Statutes to provide for suspension of a driver's license for failure to appear before the court in connection with prosecution for passing a worthless check. Section 2 creates section 832.10, Florida Statutes to provide that a payee on a worthless check may place the check for collection by a private debt collector prior to presenting the check to the state attorney for prosecution and that the payee may recover reasonable collection fees....

...o.2d at 407, I would conclude that chapter 98-223 does not violate the single subject rule for the following reasons. Chapter 98-223 contains thirteen substantive sections. Twelve sections concern drivers' licenses. The suspect section, which became section 832.10(1), Florida Statutes, is section 2, entitled, "Violations Involving Checks and Drafts." It involves assigning bad checks to a private debt collector....

...There can be no legitimate fear that section 2 was enacted through logrolling, the prevention of which is the purpose of the single subject requirement. I would conclude that chapter 98-223 does not violate that requirement. WELLS, J., concurs. NOTES [1] Section 2 states: Section 2. Section 832.10, Florida Statutes, is created to read: 832.10 Alternative to bad check diversion program; fees for collection.— (1) Prior to presenting a complaint about a dishonored check to a state attorney, a payee on such bad check may place or assign the debt evidenced by the bad check for collecti...

...Chapter 98-223 contains 15 sections of which 13 are substantive. [1] Section 1 creates section 832.09, Florida Statutes to provide for suspension of a driver's license for failure to appear before the court in connection with prosecution for passing a worthless check. Section 2 creates section 832.10, Florida Statutes to provide that a payee on a worthless check may place the check for collection by a private debt collector prior to presenting the check to the state attorney for prosecution and that the payee may recover reasonable collection fees....

...hall embrace but one subject and matter properly connected therewith." Chapter 98-223 contains thirteen substantive sections, twelve of which pertain to drivers licenses, and section 2, entitled "Violations Involving Checks and Drafts," which became section 832.10(1) and provides in part: Prior to presenting a complaint about a dishonored check to a state attorney, a payee on such bad check may place or assign the debt evidenced by the bad check for collection pursuant to this section by a private debt collector registered under part VI of chapter 559....

...most efficient method available of the action of the court. There is thus a relationship between Chapter 832, entitled "Violations Involving Checks and Drafts," and Chapter 322, entitled "Driver's Licenses." Section 2 of Chapter 98-223, which became section 832.10, quoted earlier, provides a recipient of a bad check with the alternative of attempting to collect the debt before making a complaint with the state attorney, which could result in a license suspension....

...Chapter 322, our driver's license statute, provides in section 322.251(7)(a)(1) that a driver's license revoked under section 832.09, for passing a bad check, can be reinstated if there has been payment of restitution, court costs, and fees. Those costs and fees are described in section 832.10, the provision the Critchfield panel found to have no connection with the rest of the legislation....

...of the Florida Constitution. Section 13 of Chapter 98-223 created the crime at issue in this case, driving under a permanent license revocation, a third degree felony. The supreme court's decision turned on section 2 of Chapter 98-223, which created section 832.10, involving a payee's placement of a worthless check for collection by a private debt collector prior to presenting the check to the state attorney for prosecution....