standing requirement (Florida) · Go Syfert
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standing requirement in Florida

72 Florida opinions name it 3 courts 1974–2024 7 in the last five years

The cases below were cited by Florida courts in a sentence that names this issue. Sides come from how each citing opinion treated the case (Syfertize flag on that citation), so a case can appear on both: that is where the law is contested. A red or yellow chip is the case's own overall treatment.

Followed or applied (40)

CaseFollowedCited
Sosa v. SAFEWAY PREMIUM FINANCE CO.green
fla · 2011 · cited in 15 Florida opinions naming this issue, 2012–2024
2 sentences

2024“A trial court’s decision as to whether a party has satisfied the standing requirement is reviewed de novo.” Id.

2024“To satisfy the standing requirement for a class action claim, the class representative must illustrate that a case or controversy exists between him or her and the defendant, and that this case or controversy will continue throughout the 5 existence of the litigation.” Id.

1215
Wells Fargo Bank, N.A. v. Morcomgreen
fladistctapp · 2013 · cited in 4 Florida opinions naming this issue, 2015–2018
2 sentences

2018See, e.g., Morcom, 125 So. 3d at 322 (noting: “Appellees cite Florida Supreme Court precedent dating back to the late 1800s to suggest Appellant must both hold and own the note and mortgage to satisfy the standing requirement for a foreclosure action.

2018See, e.g., Morcom, 125 So. 3d at 322 (noting: “Appellees cite Florida Supreme Court precedent dating back to the late 1800s to suggest Appellant must both hold and own the note and mortgage to satisfy the standing requirement for a foreclosure action.

44
Gorel v. Bank of New York Mellongreen
fladistctapp · 2015 · cited in 2 Florida opinions naming this issue, 2015–2018
2 sentences

2018Mellon, 165 So. 3d 44, 46 (Fla. 5th DCA 2015) (quoting Sosa v. Safeway Premium Fin.

2015“A trial court’s decision as to whether a party has satisfied the standing requirement is reviewed de novo.” Gorel v. Bank of New York Mellon, 165 So.3d 44, 46 (Fla. 5th DCA 2015) (quoting Sosa v. Safeway Premium Fin.

22
Spokeo, Inc. v. Robinsgreen
scotus · 2016 · cited in 2 Florida opinions naming this issue, 2022–2023
2 sentences

2023LEGAL ANALYSIS We affirm in all respects based on the standing analysis in Southam v. Red Wing Shoe Co., Inc., 343 So. 3d 106 , 113 (Fla. 4th DCA 2022), review denied, SC22-1052, 2022 WL 16848677 (Fla. Nov. 10, 2022) (finding the appellant lacked standing to pursue his federal FACTA claim as he did not demonstrate an injury in fact “since appellant kept the credit card receipt and there is no danger that the credit card number could result in any concrete injury to appellant”); see also Spokeo, Inc. v. Robins, 578 U.S. 330, 341 (2016) (holding that “a bare procedural violation, divorced from a

2023Because this amounts to nothing more than a ‘bare procedural violation, divorced from 4 any concrete harm,’ [Appellant] has failed to allege that he has standing to bring this lawsuit.” (quoting Spokeo, 578 U.S. at 341 )).

12
Agrico Chem. Co. v. DEPARTMENT, ETC.green
fladistctapp · 1981 · cited in 2 Florida opinions naming this issue, 1984–1986
2 sentences

1986This court, adopting the principles expressed in the Second District's opinion in Agrico Chemical Co. v. Department of Environmental Regulation, 406 So.2d 478 (Fla. 2d DCA 1981), has said that a petitioner enjoys standing to seek a section 120.57 hearing (1) if confronted with injury in fact of sufficient immediacy and (2) the injury is of the type or nature that the particular proceeding is designed to protect.

1984See, for example, Agrico Chemical Company v. Department of Environmental Regulation, 406 So.2d 478 (Fla. 2d DCA 1981); City of Panama City v. Board of Trustees of Internal Improvement Fund, 418 So.2d 1132 (Fla. 1st DCA 1982).

12
State v. JPgreen
fla · 2004 · cited in 1 Florida opinions naming this issue, 2024–2024
1 sentence

2024See, e.g., J.P., 907 So. 2d at 1113 (“Because the Second District never determined whether these juveniles have standing to assert the constitutional rights of their parents, we decline to rule on these claims.” (footnote omitted)).21 Our inconsistent approach is especially evident in the context of third-party standing.

11
Progressive Exp. v. McGRATH CHIROPRACTICgreen
fladistctapp · 2005 · cited in 1 Florida opinions naming this issue, 2024–2024
1 sentence

2024See Progressive, 913 So. 2d at 1285 (“[T]he plaintiff’s lack of standing at the inception of the case is not a defect that may be cured by the acquisition of standing after the case is filed.”); Haratz v. Dental Team of Atlantis, LLC, 372 So. 3d 282 , 286 (Fla. 4th DCA 2023) (distinguishing standing from failure to comply with a condition precedent to suit and noting that “a party’s lack of standing to bring an action is a defect that cannot be cured mid-suit”).

11
Summers v. Earth Island Institutegreen
scotus · 2009 · cited in 1 Florida opinions naming this issue, 2023–2023
1 sentence

2023Summers v. Earth Island Inst., 555 U.S. 488, 497 (2009); see ASARCO Inc. v. Kadish, 490 U.S. 605, 617 (1989) (stating that “the constraints of Article III do not apply to state courts” even when addressing a federal statute).

11
Asarco Inc. v. Kadishgreen
scotus · 1989 · cited in 1 Florida opinions naming this issue, 2023–2023
1 sentence

2023Summers v. Earth Island Inst., 555 U.S. 488, 497 (2009); see ASARCO Inc. v. Kadish, 490 U.S. 605, 617 (1989) (stating that “the constraints of Article III do not apply to state courts” even when addressing a federal statute).

11
Department of Revenue v. Kuhnleingreen
fla · 1994 · cited in 1 Florida opinions naming this issue, 2023–2023
1 sentence

2023Co. v. Kaklamanos, 843 So. 2d 885, 895 (Fla. 2003) (quoting Dep’t of Revenue v. Kuhnlein, 646 So. 2d 717, 720 (Fla.1994)), he need not allege or demonstrate an actual injury in order to have standing in a Florida state court.

11
Allstate Ins. Co. v. Kaklamanosgreen
fla · 2003 · cited in 1 Florida opinions naming this issue, 2023–2023
1 sentence

2023Co. v. Kaklamanos, 843 So. 2d 885, 895 (Fla. 2003) (quoting Dep’t of Revenue v. Kuhnlein, 646 So. 2d 717, 720 (Fla.1994)), he need not allege or demonstrate an actual injury in order to have standing in a Florida state court.

11
State Ex Rel. Dept. of General Serv. v. Willisgreen
fladistctapp · 1977 · cited in 1 Florida opinions naming this issue, 2023–2023
1 sentence

2023Had the Legislature wanted the Commission to address specific statutory factors in writing or face remand, it could have said so as it has in several other contexts. 18 Willis, 344 So. 2d 580, 590 (Fla. 1st DCA 1977)).

11
VIRGINIA GIUFFRE v. BRADLEY J. EDWARDSgreen
fladistctapp · 2017 · cited in 1 Florida opinions naming this issue, 2022–2022
1 sentence

2022See Giuffre v. Edwards, 226 So. 3d 1034, 1039 (Fla. 4th DCA 2017) (quoting the “three minimal requirements for standing” and finding that the plaintiff did not meet the third requirement); DeSantis v. Fla. Educ.

11
Renard v. Dade Countygreen
fla · 1972 · cited in 1 Florida opinions naming this issue, 2022–2022
1 sentence

2022See Renard, 261 So. 2d at 834 . 14 I suggest the three-part standing test of J.P. applies: injury-in-fact, causation, and redressability.

11
Fischer v. HSBC Bank United States, Nat'l Ass'ngreen
fladistctapp · 2018 · cited in 1 Florida opinions naming this issue, 2019–2019
1 sentence

2019Loan Tr., Series 2006-AR1, 257 So. 3d 512, 515 (Fla. 2d DCA 2018).

11
State v. Fosmiregreen
fladistctapp · 2014 · cited in 1 Florida opinions naming this issue, 2019–2019
1 sentence

2019Second, the State argues the good faith exception to the exclusionary rule applies to the State’s warrantless use of CSLI and the cell-site simulator. 2 i. Standing The State challenges the defendant’s standing for the first time on appeal. “[A]n argument regarding standing to contest the search and seizure of evidence has been subsumed into Fourth Amendment issues and may be raised for the first time on appeal.” State v. Fosmire, 135 So. 3d 1153, 1156 (Fla. 1st DCA 2014).

11
Diana Jelic v. Bac Home Loans Servicing, LPgreen
fladistctapp · 2015 · cited in 1 Florida opinions naming this issue, 2017–2017
1 sentence

2017See Jelic v. BAC Home Loans Servicing; LP, 178 So.3d 523, 525 (Fla. 4th DCA 2015) (citing Lamb v. Nationstar Mortg., LLC, 174 So.3d 1039, 1041 (Fla. 4th DCA 2015)). 4 .

11
Craig D. Lamb v. Nationstar Mortgage, LLCgreen
fladistctapp · 2015 · cited in 1 Florida opinions naming this issue, 2017–2017
11
Elsman v. HSBC BANK USAgreen
fladistctapp · 2015 · cited in 1 Florida opinions naming this issue, 2017–2017
11
Paul v. Blakegreen
fladistctapp · 1979 · cited in 1 Florida opinions naming this issue, 2016–2016
11
Pinecrest Lakes, Inc. v. Shidelgreen
fladistctapp · 2001 · cited in 1 Florida opinions naming this issue, 2016–2016
11
Greenberg v. MAHONEY ADAMS & CRISER, PAgreen
fladistctapp · 1993 · cited in 1 Florida opinions naming this issue, 2012–2012
11
Winston v. Brogangreen
flsd · 1994 · cited in 1 Florida opinions naming this issue, 2012–2012
11
Foundation for the Developmentally Disabled, Inc. v. Step by Step Early Childhood Education & Therapy Center, Inc.green
fladistctapp · 2010 · cited in 1 Florida opinions naming this issue, 2011–2011
11
Fox v. Professional Wrecker Operators of Florida, Inc.green
fladistctapp · 2001 · cited in 1 Florida opinions naming this issue, 2011–2011
11
Olen Properties Corp. v. Mossgreen
fladistctapp · 2008 · cited in 1 Florida opinions naming this issue, 2011–2011
11
Gregory v. Indian River Countygreen
fladistctapp · 1992 · cited in 1 Florida opinions naming this issue, 2008–2008
11
St. Joe Paper Co. v. COMMUNITY AFFAIRSgreen
fladistctapp · 1995 · cited in 1 Florida opinions naming this issue, 2007–2007
11
Ybor III, Ltd. v. FLA. HOUSING FIN. CORP.green
fladistctapp · 2003 · cited in 1 Florida opinions naming this issue, 2006–2006
11
City of Sunrise v. Broward Countygreen
fladistctapp · 1985 · cited in 1 Florida opinions naming this issue, 2005–2005
11
United States v. One-Sixth Share of Bulger in All Present & Future Proceeds of Mass Millions Lottery Ticket No. M246233green
ca1 · 2003 · cited in 1 Florida opinions naming this issue, 2004–2004
11
Adoption of Dianegreen
mass · 1987 · cited in 1 Florida opinions naming this issue, 2004–2004
11
State v. Sucogreen
fla · 1988 · cited in 1 Florida opinions naming this issue, 2003–2003
11
Heggs v. Stategreen
fladistctapp · 1998 · cited in 1 Florida opinions naming this issue, 2000–2000
11
Televisual Comm. v. St. Dept. of Laborgreen
fladistctapp · 1995 · cited in 1 Florida opinions naming this issue, 1999–1999
11
Cole Vision v. Dept. of Bus. and Prof.green
fladistctapp · 1997 · cited in 1 Florida opinions naming this issue, 1999–1999
11
SOUTH END IMP. GROUP, INC. EX REL. BANK OF NY v. Mullikengreen
fladistctapp · 1992 · cited in 1 Florida opinions naming this issue, 1998–1998
11
In re Forfeiture of One 40' Fiberglass Boat, White in Color with Black Bottom, Florida Registration FLO346EM, Hull No. Per 40014M1Cgreen
fladistctapp · 1984 · cited in 1 Florida opinions naming this issue, 1998–1998
11
All Risk Corp. of Florida v. Stategreen
fladistctapp · 1982 · cited in 1 Florida opinions naming this issue, 1997–1997
11
Castaneda v. Partidagreen
scotus · 1977 · cited in 1 Florida opinions naming this issue, 1987–1987
11

Distinguished, questioned or overruled (0)

CaseNegativeCited
No negative-treatment citations attached to this issue in Florida. Read the followed side critically anyway.

Also cited on this issue (40)

CaseCitedYears
Lujan v. Defenders of Wildlife green
scotus · 1992
2 sentences

2024For example, as noted above we adopted the three-part standing test established by the United States Supreme Court in Lujan v. Defenders of Wildlife, 504 U.S. 555 , in J.P.

2022The United States Supreme Court in TransUnion recently reiterated its adherence to the three-part standing test, as cited in State v. J.P.: “[T]o establish standing, a plaintiff must show (i) that he suffered an injury in fact that is concrete, particularized, and actual or imminent; (ii) that the injury was likely caused by the defendant; and (iii) that the injury would likely be redressed by judicial relief.” TransUnion, 141 S. Ct. at 2203 (citing Lujan, 504 U.S. at 560-61 ).

22022–2024
Miguel Tilus, Alta Tilus, Rose A. Joaseus and Kesner Joaseus v. AS Michai LLC green
fladistctapp · 2015
2 sentences

2018The cases Appellees cite are not persuasive because the supreme court decided the cases prior to the adoption of the now-instructive and binding Florida UCC”); Tilus, 161 So. 3d at 1286 .

2018The cases Appellees cite are not persuasive because the supreme court decided the cases prior to the adoption of the now-instructive and binding Florida UCC”); Tilus, 161 So. 3d at 1286 .

22018–2018
Munoz v. City of Coral Gables green
fladistctapp · 1997
2 sentences

2004Id. at 1286-87 .

1998Id. at 1286-87 .

21998–2004
Rakas v. Illinois green
scotus · 1979
2 sentences

1988NOTES [1] Rakas v. Illinois, 439 U.S. 128 , 99 S.Ct. 421 , 58 L.Ed.2d 387 (1978), reh'g denied, 439 U.S. 1122 , 99 S.Ct. 1035 , 59 L.Ed.2d 83 (1979), in which the United States Supreme Court subsumed the standing requirement under substantive fourth amendment doctrine in determining whether a defendant is entitled to claim the protections of the exclusionary rule. [2] In Jones, the Court held that defendants who are charged with crimes of possession were not required to establish a legitimate expectation of privacy in the premises searched or the property seized because they were entitled to a

1988NOTES [1] Rakas v. Illinois, 439 U.S. 128 , 99 S.Ct. 421 , 58 L.Ed.2d 387 (1978), reh'g denied, 439 U.S. 1122 , 99 S.Ct. 1035 , 59 L.Ed.2d 83 (1979), in which the United States Supreme Court subsumed the standing requirement under substantive fourth amendment doctrine in determining whether a defendant is entitled to claim the protections of the exclusionary rule. [2] In Jones, the Court held that defendants who are charged with crimes of possession were not required to establish a legitimate expectation of privacy in the premises searched or the property seized because they were entitled to a

21988–2003
Hayes v. Guardianship of Thompson green
fla · 2006
1 sentence

2024But a few years later in Johnson, we stated broadly that “standing ‘requires a would-be litigant to demonstrate that he or she reasonably expects to be affected by the outcome of the proceedings, either directly or indirectly.’ ” 78 So. 3d at 1314 (quoting Hayes, 952 So. 2d at 505 ).

12024–2024
Johnson v. State green
fla · 2012
1 sentence

2024But a few years later in Johnson, we stated broadly that “standing ‘requires a would-be litigant to demonstrate that he or she reasonably expects to be affected by the outcome of the proceedings, either directly or indirectly.’ ” 78 So. 3d at 1314 (quoting Hayes, 952 So. 2d at 505 ).

12024–2024
TransUnion LLC v. Ramirez green
scotus · 2021
1 sentence

2022The United States Supreme Court in TransUnion recently reiterated its adherence to the three-part standing test, as cited in State v. J.P.: “[T]o establish standing, a plaintiff must show (i) that he suffered an injury in fact that is concrete, particularized, and actual or imminent; (ii) that the injury was likely caused by the defendant; and (iii) that the injury would likely be redressed by judicial relief.” TransUnion, 141 S. Ct. at 2203 (citing Lujan, 504 U.S. at 560-61 ).

12022–2022
Boucher v. Novotny green
fla · 1958
1 sentence

2020In Boucher, the Florida Supreme Court reaffirmed that “where municipal officials threaten or commit a violation of municipal ordinances which produces an injury to a particular citizen which is different in kind from the injury suffered by the people of the community as a whole[,] then such injured individual is entitled to injunctive relief in the absence of an adequate legal remedy.” 102 So. 2d at 134 .

12020–2020
Allen v. State green
fladistctapp · 2013
1 sentence

2020Detournay, 127 So. 3d at 877 . 3 These cases set forth the standing requirement for equitable zoning enforcement actions.

12020–2020
Collier v. State green
fladistctapp · 2017
1 sentence

2020Our decision is controlled in part by PennyMac Corp. v. Frost, 214 So. 3d 686 (Fla. 4th DCA 2017), which recognizes the existence of the standing defense which the purchaser sought to litigate.

12020–2020
Bank of New York Mellon Trust Company, N.A. v. Dennis M. Conley green
fladistctapp · 2016
1 sentence

2019Id.

12019–2019
Chuck v. City of Homestead Police Dept. green
fladistctapp · 2004
12017–2017
Velez v. MIAMI-DADE COUNTY POLICE DEPT. green
fla · 2006
1 sentence

2017Velez v. Miami-Dade Police Dep’t., 934 So.2d 1162 (Fla. 2006); Chuck v. City of Homestead Police Dep’t, 888 So.2d 736 (Fla. 3d DCA 2004).

12017–2017
Sapp v. State green
fladistctapp · 2016
1 sentence

2017A foreclosure plaintiff satisfies the standing requirement when, at trial, it presents “competent, substantial evidence that it has standing to foreclose.” Id.

12017–2017
Taylor v. Cedar Key Special Water & Sewerage District neutral
fladistctapp · 1991
12016–2016
City of Tampa v. Addison green
fladistctapp · 2007
12016–2016
School Bd. of Volusia County v. Clayton green
fla · 1997
12015–2015
Kumar Corp. v. Nopal Lines, Ltd. green
fladistctapp · 1985
12012–2012
Dade County v. Baker green
fladistctapp · 1978
12012–2012
Peace River/Manasota Regional Water Supply Authority v. IMC Phosphates Co. green
fladistctapp · 2009
12011–2011
Reily Enterprises, LLC v. Dept. of Environmental Protection green
fladistctapp · 2008
12011–2011
State v. Gray green
fla · 1983
12007–2007
Broadrick v. Oklahoma green
scotus · 1973
12007–2007
Matter of Surface Water Mgmt. Permit green
fladistctapp · 1987
12004–2004
Cochran v. Jones green
fladistctapp · 1998
12004–2004
NAACP, INC. v. Florida Bd. of Regents green
fladistctapp · 2002
12003–2003
NORTH FLA. REGIONAL HOSP., INC. v. Douglas green
fladistctapp · 1984
12002–2002
Eisenstadt v. Baird green
scotus · 1972
12002–2002
Heggs v. State green
fla · 2000
12000–2000
Thomas v. State neutral
fladistctapp · 1988
11999–1999
Ward v. Board of Trustees green
fladistctapp · 1995
11999–1999
Fla. Medical Ass'n v. Dept. of Prof. Regulation green
fladistctapp · 1983
11993–1993
State Farm Mut. Auto. Ins. Co. v. KAW green
fla · 1991
11992–1992
Florida Home Builders Ass'n v. Dept. of Labor green
fla · 1982
11990–1990
Jacobs v. Alabama green
scotus · 1979
11988–1988
Florida Patient's Comp. Fund v. Von Stetina green
fla · 1985
11986–1986
Lenier v. Schulstead green
fladistctapp · 1982
11984–1984
State, Department of Health & Rehabilitative Services v. Professional Firefighters of Florida, Inc. green
fladistctapp · 1979
11981–1981
Jones v. United States red
scotus · 1960
11980–1980
Aiello v. City of Wilmington, Del. green
ded · 1976
11978–1978

Statutes the citing opinions construe

FL § 120.57 (9) FL § 673.3011 (9) FL § 673.3091 (8) FL § 120.56 (7) FL § 673.2051 (7) FL § 120.52 (5) FL § 120.569 (5) FL § 120.68 (5) FL § 671.201 (4) FL § 120.54 (3) FL § 163.3215 (3) FL § 932.701 (3)

Counted by distinct opinions that both name this issue and are annotated to the section; sections every opinion cites regardless of issue are not filtered here, so read the counts against the total above.

Where else courts name it

TX 479 (1978–2026) IL 242 (1869–2026) CA 232 (1968–2026) PA 166 (1894–2026) MI 156 (1970–2025) NY 116 (1899–2026) IN 112 (1973–2025) CO 81 (1977–2026) TN 78 (1980–2026) WA 78 (1978–2025) FL 72 (1974–2024) CT 60 (1978–2026) OH 54 (1975–2026) ME 53 (1975–2025) VA 51 (1876–2026) VT 51 (1909–2026) UT 43 (1987–2024) WI 43 (1974–2026) NJ 43 (1854–2025) RI 39 (1968–2023) ID 39 (1908–2026) NE 38 (1899–2025) MD 37 (1970–2025) MA 36 (1975–2025) IA 36 (1972–2025) KS 36 (1964–2026) AL 34 (1977–2025) AZ 34 (1977–2026) GA 32 (1939–2026) MO 32 (1977–2024) NC 32 (1917–2023) MT 31 (1962–2026) HI 30 (1970–2025) WY 29 (1986–2025) DC 28 (1975–2024) DE 26 (1993–2025) AK 25 (1970–2024) MN 22 (1964–2016) NM 19 (1975–2024) OR 18 (1974–2026) KY 17 (2005–2023) WV 16 (1988–2026) ND 15 (1976–2022) NH 14 (1931–2024) LA 13 (1975–2025) SC 11 (1993–2023) SD 11 (1995–2021) OK 10 (1979–2018) NV 8 (2011–2021) VI 7 (1996–2016) MS 7 (1988–2019) AR 6 (2001–2020) GU 4 (2022–2025) MP 2 (1985–2023)

Opinions by the citing court's state. A doctrine retained in one state and abandoned in another shows up here as a year span that stalls.

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