In Murphy v. Mack, 358 So.2d 822 (Fla. 1978), the Court considered whether the county sheriff was a "public employer" and deputy sheriffs "public employees" under the Florida statutory scheme of collective bargaining. The Court held that the county sheriff was a public employer; however, it held that deputy sheriffs were not public employees. Id. at 824 ("We find that the language employed by the Legislature in Chapter 447, Florida Statutes (1975), does not reveal a legislative intent to include appointed deputy sheriffs within the definition of 'public employee.'"). In Service Employees International Union Local 16, AFL-CIO v. Public Employees Relations Commission, et al., 752 So.2d 569, No. SC 94427 (Fla. January 13, 2000) the Court was presented with a similar question certified by the Fifth District involving public employees who have historically been categorized as "deputies": Are deputy court clerks, unlike deputy sheriffs, public employees within the contemplation of section 447.203(3), Florida Statutes? 752 So.2d at 570. The Court answered affirmatively and held that deputy clerks were in fact public employees entitled to collective bargaining rights under section 447.203, Florida Statutes (1997). The Court acknowledged that in the past a "deputy" may have occupied a special place inasmuch as a "deputy functioned as the alter ego, so to speak, or second in command to the principal." Id. 752 So.2d at 572. In this respect, the Court noted, deputies were in fact managerial-level employees who could take charge in the principal's absence. However, the Court found: Times have changed and the public officials who once required one or two deputies to assist them in their tasks now might require a host of assistants. Further, the range of tasks performed by these workers has expanded and the tasks themselves have become specialized. For instance, a clerk of court today might employ a score or more skilled workers as bookkeepers, archivists, filing clerks, typists, and receptionists. In deference to tradition, such employees are often still called "deputies," but their positions bear little resemblance to the deputies of old. As noted by the district court below, the deputies of today often "look surprisingly like other public employees." Various public officials are currently authorized under Florida Statutes to appoint deputies--e.g., sheriffs, clerks of court, property appraisers, and tax collectors. Id. In Service Employees, the Court further observed that "Murphy appears to have exalted form over substance in contravention of the plain language and broad purpose of the Act." The Court also noted that the "appointed/employed" distinction was of little significance under chapter 447, Florida Statutes (1997), because the definition of "public employee" in section 447.203 itself drew no such distinction. The Court explained that there was simply no basis for excluding a "deputy" from the protection of chapter 447: There are two basic categories of persons who work for the public: (1) employees in the ordinary sense of the word; (2) managerial level employees (as well as various other specialized workers). Employees in the ordinary sense of the word are considered "public employees" under the Act and their right to collectively bargain is protected. Managerial level employees, on the other hand, are not considered "public employees" and their right to collectively bargain is not protected by the Act. 752 So.2d at 572.