LAURA L. WHITESIDE, PETITIONER,
v.
SCHOOL BOARD OF ESCAMBIA COUNTY, RESPONDENT
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Laura Whiteside, counsel for the Mason Estate, challenges a trial court order imposing sanctions against her. The court granted the petition for certiorari and quashed the sanctions order because the trial court violated fundamental legal requirements by acting on motions filed by the School Board despite the Board never being admitted as a party to the case.
The court held that the trial court departed from the essential requirements of law by acting upon the School Board's motions without first granting party status. Under the general rule, one not a party to a case has no standing to request relief from the court, and no exception to this rule applied to the circumstances presented.
[1] A party not formally joined to a legal action lacks standing to request relief from the court.
[2] A court departs from the essential requirements of law by entertaining motions from a non-party without first granting party status.
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Join FLexlaw to unlock all legal intelligence“Persons who are not parties of record to a suit have no standing therein which will enable them to take part in or control the proceedings.”
Establishes the fundamental rule that non-parties lack standing to participate in litigation
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Join FLexlaw to unlock all legal intelligenceIn a circuit court case styled Pensacola News Journal v. Estate of Mason, the Escambia County School Board filed a motion to join as a party, but the …
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KAHN, J.
Laura L. Whiteside (Petitioner) petitions for a writ of certiorari to review a trial court order granting a motion for sanctions filed by the Escambia County School Board (Respondent). Because the trial court departed from the essential requirements of law, we grant the petition and quash the trial court’s order. This matter arises from a circuit court case, styled Pensacola News Journal v. Estate of Mason, Case No. 00-2005-CA-01. Although Respondent filed a motion to join in that case, the trial court never acted on the motion. Petitioner, counsel for the Mason Estate, consistently, throughout the proceedings, advanced her argument that Respondent was not a party.
Nevertheless, the trial court entertained several motions filed by Respondent, and ultimately granted a motion for sanctions against Petitioner, bottomed upon Petitioner’s alleged violation of an earlier court order. Under the general rule, one not a party to a case has no standing to request relief from the court. See Warshaw-Seattle, Inc. v. Clark, 85 So. 2d 623, 625 (Fla.1955) (“ ‘Persons who are not parties of record to a suit have no standing therein which will enable them to take part in or control the proceedings. If they have occasion to ask relief in relation to the matters involved, they must either contrive to obtain the status of parties in such suit or they must institute an independent suit.’ ”) (quoting 39 Am.Jur. Parties § 55).
In this case, We find no exception to the general rule, such as, for example, a situation involving discovery from a nonparty. See e.g., Jerry’s South, Inc. v. Morran, 582 So. 2d 803, 804 (Fla. 1st DCA 1991) (holding that a motion for protective order filed by a nonparty should be granted when discovery sought from that nonparty is overly broad).
Consequently, the trial court departed from the essential requirements of law in acting upon Respondent’s requests, without first acting to grant party status to Respondent.
We GRANT the petition for certiorari, and QUASH the trial court’s order granting sanctions. We deny Respondent’s motion for attorney’s fees.
WOLF and BENTON, JJ., CONCUR.
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