Robert R. Reynolds v. Leon County Energy Improvement District, etc., 176 So. 3d 254

Appellate challenge to a circuit court judgment validating a proposed bond issue for the Leon County Energy Improvement District.
The Supreme Court affirms validation on the merits but remands for the district to amend the financing agreement to remove references to judicial foreclosure and to file the amended agreement after board approval.
The Court concludes that prior precedent (Meyers) allowing parties who did not appear in the trial court to appeal bond validations is incorrect.
The Court interprets sections 75.05, 75.06, 75.07, and 75.08 as requiring that persons wishing to contest bond validation must appear and plead in the circuit court to obtain party status and appellate standing.
The Court formally recedes from Meyers and from three later decisions that relied on it (Rowe, Lozier, Bruns).
Justice Canady dissents only as to disposition, arguing the proper remedy for lack of standing is dismissal of the appeal rather than resolving the merits.

Issue	Plaintiff's Argument	Defendant's Argument	Held
Validity of proposed bonds	Appellant challenged bond validation on unspecified grounds	Circuit court and district defended the financing and validation	Court AFFIRMED the circuit court's validation on the merits
Financing agreement language permitting judicial foreclosure	Appellant objected to foreclosure language as improper	District relied on its financing agreement as drafted	Court REMANDED: district must amend agreement to remove all references to judicial foreclosure and file the amended agreement after board approval
Appellant's standing to appeal after failing to appear below	Appellant relied on Meyers to assert right to appeal despite not participating in trial court	Respondents argued statute requires participation in circuit court to be a party and to appeal	Court HELD that persons must appear and plead in circuit court to obtain party status and appellate standing; receded from Meyers and its progeny
Proper disposition when appellant lacks standing	Appellant implicitly sought resolution on the merits	Respondents urged dismissal for lack of standing	Majority resolved merits but remanded for amendment; dissent argued the appeal should be DISMISSED for lack of standing

Thomas v. Clean Energy Coastal Corridor, 176 So.3d 249 (Fla. 2015) (similar financing agreement; court required removal of judicial foreclosure language)
State v. City of Venice, 2 So.2d 365 (Fla. 1941) (remand to amend resolution and bonds where language was too broad)
Meyers v. City of St. Cloud, 78 So.2d 402 (Fla. 1955) (former rule allowing nonappearing citizens to appeal; receded from)
Rowe v. St. Johns Cnty., 668 So.2d 196 (Fla. 1996) (followed Meyers; receded from)
Lozier v. Collier Cnty., 682 So.2d 551 (Fla. 1996) (followed Meyers; receded from)
Bruns v. Cnty. Water-Sewer Dist., 354 So.2d 862 (Fla. 1978) (followed Meyers; receded from)
Bondi v. Tucker, 93 So.3d 1106 (Fla. 1st DCA 2012) (principle that failure to participate in trial court normally precludes appeal)
Ramos v. Philip Morris Cos., Inc., 714 So.2d 1146 (Fla. 3d DCA 1998) (non-named class members must intervene to gain standing to appeal)