Bondi v. Tucker, 93 So. 3d 1106

Attorney General Bondi sought review of a circuit court final declaratory and injunctive judgment against the Florida Department of Corrections regarding budget proviso language in the 2011-2012 Appropriations Act.
The Attorney General appeared only as counsel for the DOC, not as a party, and did not intervene in the proceedings below.
The challenged proviso directed DOC to issue a request for proposals to privatize twenty-nine facilities in Region IV.
The circuit court held the privatization proviso unconstitutional and enjoined further implementing steps; the AG filed a notice of appeal on October 31, 2011, claiming capacity as state attorney general.
The court dismissed the appeal for lack of standing, concluding the AG lacked authority to initiate an appeal on her own as a non-party.
The Court noted potential intervention, post-judgment intervention, or certiorari as possible remedies, but none were pursued by the AG.

Issue	Plaintiff's Argument	Defendant's Argument	Held
Does the Attorney General have standing to appeal a circuit court judgment?	Bondi argues as AG she may initiate appeals to defend public interests.	The state officer lacked party status and could not appeal without intervention.	No standing; appeal dismissed.
Was intervention available to allow AG to participate and appeal?	AG could intervene as a party to defend statutes deemed unconstitutional.	AG never sought intervention; intervention is required to pursue appeal rights.	Intervention not pursued; no right to appeal.
Could certiorari be used as a remedy for AG to challenge the circuit court order?	Certiorari could substitute for ordinary appellate procedures to review the decision.	Certiorari unavailable where an adequate remedy exists and record shows mootness.	Not warranted; not an adequate remedy here.

Portfolio Investments Corp. v. Deutsche Bank Nat’l Trust Co., 81 So.3d 534 (Fla. 3d DCA 2012) (non-parties generally lack standing to appeal)
Morrell v. Nat’l Health Investors, Inc., 876 So.2d 580 (Fla. 1st DCA 2004) (non-named parties cannot seek appellate review)
Stas v. Posada, 760 So.2d 954 (Fla. 3d DCA 1999) (appellate review limited to named parties)
Ramos v. Philip Morris Cos., Inc., 714 So.2d 1146 (Fla. 3d DCA 1998) (non-named class members must intervene to gain standing)
Barnett v. Barnett, 705 So.2d 63 (Fla. 4th DCA 1997) (non-party cannot transfer jurisdiction to appellate court)
Forcum v. Symmes, 133 So. 88 (Fla. 1931) (early articulation on standing/participation)
Watson v. Claughton, 34 So.2d 243 (Fla. 1948) (AG heard on intervention petition; denial became final without review)
State ex rel. Shevin v. Kerwin, 279 So.2d 836 (Fla. 1973) (AG may intervene where statute is unconstitutional on appeal)
State ex rel. Shevin v. Yarborough, 257 So.2d 891 (Fla. 1972) (AG's broad authority; separation of powers)
State ex rel. Moodie v. Bryan, 50 Fla. 293 (Fla. 1905) (historical basis for AG’s standing to litigate matters of public interest)