878 (Fla. 4th DCA 2002) (finding local ordinance charging BellSouth a land occupation fee was not impliedly preempted by State legislation); Lowe v. Broward County, 766 So.2d 1199, 1207 (Fla. 4th DCA 2000) (finding a county ordinance recognizing domestic partner relations and allowing for benefits to be paid to domestic partners of county employees was not impliedly preempted by state marriage laws), rev. denied, 789 So.2d 346 (Fla.2001). The protection of the welfare of the local citizenry through the adoption of generally applicable land development regulations has been exclusively within the province of local government. Implied constraints within these particular areas should be even more carefully scrutinized. Cf. HTS Ind., Inc. v. Broward County, 852 So.2d 382 (Fla. 4th DCA 2003) (<HOLDING>). Applying the sanctions of the Bert Harris Act
recognizing that the question of whether courts should extend chevron deference to an agencys interpretation of an explicit preemption provision remains open holding that general categorical release clauses are narrowly construed recognizing that texas courts narrowly construe the intentional infliction of emotional distress doctrine recognizing that in areas historically legislated by the states the courts must narrowly construe any express preemption clauses so that if an ambiguity exists as to preemption nonpreemption should be found holding that courts should liberally construe the requirements of rule 3