Florida v. United States was a Supreme Court case that determined whether or not the federal government could unilaterally dissolve a state of the United States of America. The case was one of several precipitated by the National Reorganization Act of 2061, which redrew state borders due to the effects of climate change. Although most of the boundary changes were done with the consent of the states involved, this was not the case with Florida due to an incident known as the Florida Fraud. The court ruled that unilateral dissolution (ie, without the consent of the state) was unconstitutional.
Over the preceding decades, many states had seen sea level rise and other disastrous weather events that had radically altered their land territory and populations. One such state was Florida, which was by far the most impacted by these events, having lost over 40% of its land territory to the sea, swamps, and other factors such as storms which rendered the state nearly uninhabitable. Florida's decline was hastened by the Relocation Act of 2049, which granted federal assistance in relocation to residents of any state impacted by climate change who wished to move to another state. In 2055, the Florida State Legislature passed the controversial "Expulsion Law" which was used by the state government to force resistant residents to out of the Disaster Zone to safer territory. The Southeastern Migration Compact allowed for entire communities to relocate to newly built homes in neighboring states. By the late 2050s, Florida's population had dwindled to the low hundreds of thousands. It soon became the least populated state in the union, a fact which would be confirmed in the 2060 census.
However, during this time, the Florida Independence Party rose to power in state government, largely due to a lack of electoral participation from fleeing Floridians. The Independence Party resisted attempts from the federal government to dissolve Florida by either merging its lands into neighboring Georgia, turning it into a territory, or placing it under martial law. Florida successfully sued the Escalante administration when President Escalante placed the state under martial law. However, this case was largely decided due to fears of abuse of martial law in other states which were experiencing political violence and unrest. After the 2060 Census, Florida had a population of 84,606. Governor Jameson Young of the Independence Party arranged the transfer of most of Florida's inhabited land to Georgia. This left the state of Florida with a population of 109 people, among them Governor Young and his family, and his business partners. Young, a transplant from Indiana, had moved to Florida and bankrolled the FIP with the intention of severing the state and leaving a rump state which would have full representation in Congress but no voter base, thus allowing him and his partners to have a oversized say in federal affairs. After successfully executing this scheme, Young abolished the Florida State Legislature, leaving himself as the only vestige of statewide government. The state's senators were his husband Portnoy Young and his FIP co-financier Dennis Rinaldi. Florida's Congressman was his nephew Don DeMaio.
In response, Congress included in the Reorganization Act a provision which would dissolve the State of Florida and replace it with the unorganized Territory of Florida, to be overseen by the federal government, with habitable areas owned by Young and his associates annexed to Georgia. Although this decision was made with near unanimous support in Congress (passed 602-18-5 in the House, 105-3 in the Senate) and was very popular nationwide, there were concerns about the federal government's authority to make such a decision, and whether it could be used against a "real" state. Florida sued, with the Supreme Court having original jurisdiction. Florida argued that the federal government lacked the constitutional authority to dissolve a state, and cited
Texas v. White as precedent that states entered into an "indissoluble relation." The U.S. argued that there was no prohibition against the dissolution of states, as the constitution was silent on the issue. The Constitution only spoke on the admission and creation of states.
The majority opinion, written by Chief Justice Azari, upheld
Texas v. White's interpretation of the "indissoluble relation", citing Article IV of the Constitution, which states "the United States shall guarantee to every state...a republican form of government" and that "the citizens of each state shall be entitled to all privileges and immunities of citizens in the several states." A concurring opinion by Justice Papik agreed that the federal government had no power to dissolve a state, but argued that since Florida no longer had a state government to speak of, so the Congress was the only authority on the matter. Thus, even if the consent of both parties was necessary, the state had rendered itself defunct and its consequent silence was tantamount to agreement with all decisions of the federal government. The dissent, written by the most junior justice of the court, Carlos Fremont Jackson, agreed with the federal government's argument that there is nothing prohibiting the dissolution of a state. Furthermore, Fremont wrote that Florida had become "an obscenity" and that it's continued existence constituted an act of domestic violence against the other states. A partial dissent by Justice Tang argued that although the federal government had no explicit power to dissolve a state, but it was necessary to dissolve Florida in order to preserve the national interest.
Legal scholars have described the case as a quagmire with no clear answer. The opinions produced by the court were thoroughly criticized for being tailored to meet political ends. Justices who wanted Florida dissolved but did not wish to set a precedent for dissolution dissented. Justices who supported dissolution in general and justices who opposed Florida dissolution but were agreeable to dissolution in principle assented. The decision was met with public outrage and resulted in a series of actions from the federal government which prompted further lawsuits. First, both houses of Congress unseated Florida's members. Their suits were dismissed by the courts as political matters, since Congress can determine its own qualifications for membership. Secondly, Congress introduced a constitutional amendment to allow for state dissolution. Thirdly, Congress eliminated all disbursement to Florida from the federal budget. Furthermore, President Razak instituted martial law in Florida, in defiance of
Parilla v. Chow. The latter two incidents prompted lawsuits from Florida, but the cases were never heard, as the dissolution amendment was ratified by the states and used to eliminate Florida with extreme haste. Florida was the first of five states which would be dissolved by the federal government unilaterally before the passage of the 38th Amendment in 2078, which introduced stricter requirements and regulations necessary to dissolve a state.