Mr. Garcia, the Dade property appraiser, denied an application for a homestead tax exemption sought by the Andonies. The Andonies are foreign nationals in the United States on visas. They sought the tax exemption based on the U.S. citizenship of their three minor children, who were all born in Miami and who all live in the home with their parents. The Andonies challenged Mr. Garcia's decision and a review board granted them the tax exemption. When Mr. Garcia challenged that decision in court, both the trial court and the Third District Court of Appeal ruled for the Andonies.