On April 25, 2018, in Sanchez v. Miami-Dade County, No. 3D16-959, the Florida Third DCA ruled that the defendant county had sovereign immunity under Fla. Stat. section 768.28(9) which barred the plaintiff’s negligent security claims. The plaintiff alleged that the county had negligently failed to allocate off-duty police officers as security to protect partygoers at a birthday party held in a county park. The Third DCA affirmed the trial court’s summary judgment in the county’s favor, concluding that the county’s sovereign immunity protected its policy and planning decisions about where to allocate its limited police resources.
