DEPARTMENT OF CHILDREN AND FAMILIES
v.
STATE OF FLORIDA AND SONIA RENEA CLAY
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The Department of Children and Families (DCF), a non-party to a criminal case, challenged a monetary judgment entered against it by the trial court. The district court held that the trial court lacked jurisdiction to enter a judgment against a non-party and granted certiorari relief, quashing the judgment.
The trial court lacked jurisdiction to enter a judgment against DCF because DCF was not a party to Clay's criminal case and had not been brought into the proceeding.
[1] A trial court lacks jurisdiction to enter a monetary judgment against a non-party to a criminal case.
[2] A non-party to a criminal proceeding cannot have its rights adjudicated without being made a party to the action.
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Join FLexlaw to unlock all legal intelligence“It is so fundamental to our concept of justice that a citation of supporting authorities is unnecessary to hold that the rights of an individual cannot be adjudicated in a judicial proceeding to which he has not been made a party and from which he has literally been excluded by the failure of the moving party to bring him properly into court.”
Establishes the fundamental principle that a court cannot adjudicate the rights of someone who is not a party to the proceeding
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Join FLexlaw to unlock all legal intelligenceIn 2016, Sonia Clay pleaded no-contest to obtaining public benefits through fraud and was sentenced to five years' probation. The trial court ordered …
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TRAVER, J.
The Department of Children and Families (“DCF”), a non-party to a criminal felony case, petitions for certiorari review of a monetary judgment entered against it. Because the trial court did not have jurisdiction to enter the judgment, we grant the petition and quash the judgment.
In 2016, the trial court accepted Sonia Clay’s no-contest plea to obtaining public benefits through fraud. It withheld adjudication and sentenced her to five years’ probation. The trial court also ordered her to pay DCF $15,658.24 in restitution. Five years later, the trial court ordered Clay to appear at a violation of probation hearing to explain why she had not fully paid the ordered restitution. At the hearing, Clay apparently established that she had not only paid the ordered restitution, but an additional $5,978.70.
The trial court unsuccessfully attempted to telephone DCF, a non-party which had not received notice of, and was not present at, the hearing. Two months later, without further hearing and on its own initiative, the trial court entered a judgment against DCF for $5,978.70.
DCF petitions for certiorari relief, alleging that when the trial court entered a judgment against it, the trial court departed from the essential requirements of law and caused it injury irremediable on direct appeal. We agree. 2 The trial court lacked jurisdiction to enter a judgment against DCF, a non-party to Clay’s criminal case. See Alger v. Peters, 88 So. 2d 903, 906 (Fla. 1956) (“It is so fundamental to our concept of justice that a citation of supporting authorities is unnecessary to hold that the rights of an individual cannot be adjudicated in a judicial proceeding to which he has not been made a party and from which he has literally been excluded by the failure of the moving party to bring him properly into court.”); Chase v. Turner, 560 So. 2d 1317, 1319 (Fla. 1st DCA 1990) (“[A] court cannot award judgment against someone who is not a party to the action.”). We therefore quash the judgment on appeal.
PETITION GRANTED; ORDER QUASHED.
LAMBERT, C.J., and EISNAUGLE, J., concur. 3
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Citator
Authorities Cited
- Mason W. Alger v. Peters, 88 So. 2d 903 (Fla. 1956)
- Chase v. Turner, 560 So. 2d 1317 (Fla. 1st DCA 1990)