The issues in this case are: (1) whether three forms used by the Florida Commission on Human Relations are unpromulgated rules; (2) whether Petitioners, M.B.F. and Citizens for Pets in Condos, Inc., are substantially affected by the forms they seek to challenge as unpromulgated rules; and (3) whether, if Petitioners prevail, they are entitled to attorney’s fees and costs pursuant to section 120.595(4), Florida Statutes (2011).1/Forms used by FCHR in processing housing discrimination cases do not consitute unpromulgated rules.
