ACCELA, INC., AND CRW SYSTEMS, INC., D/B/A CRW ASSOCIATES, APPELLANTS,
v.
SARASOTA COUNTY AND CSDC SYSTEMS, INC., APPELLEES
AI-generated. These summaries, headnotes, and key points are machine-generated and may contain errors or omissions. Always verify against the full opinion text below. Not legal advice.
Accela and CRW appealed a summary judgment dismissing their complaint challenging Sarasota County's award of computer software contracts to CSDC Systems without competitive bidding. The appellate court reversed, holding that the plaintiffs had standing as potential competitors to challenge whether the County properly followed its procurement code.
The plaintiffs had standing to proceed because they were potential competitors with a right to seek determination of whether competitive bidding was required. Standing exists when a party has a sufficient stake in a justiciable controversy with a legally cognizable interest affected by the litigation outcome.
[1] Potential competitors have standing to challenge whether competitive bidding was required for government contracts.
[2] A party has standing if they possess a sufficient stake in a justiciable controversy with a legally cognizable interest that would be affected by the litigation's outcome…
Previewing 2 of 3 headnotes on this case. FLexlaw’s editorially structured points of law — every proposition, pinpointed — are reserved for members.
Join FLexlaw to unlock all legal intelligence“standing depends on whether a party has a sufficient stake in a justiciable controversy, with a legally cognizable interest which would be affected by the outcome of the litigation”
Establishes the legal standard for determining standing that the trial court failed to apply
Previewing 1 of 3 key quotes on this case — the court’s exact language, pinpointed for members.
Join FLexlaw to unlock all legal intelligenceAccela and CRW alleged that Sarasota County improperly awarded contracts to CSDC Systems for computer software and maintenance services without obtain…
The full statement of facts, procedural history, and disposition for this case are member content.
Join FLexlaw to unlock all legal intelligence© FLexlaw, Inc. — AI-generated enrichments are proprietary. All rights reserved.
Explore caselaw by topic → Browse Competitive Bidding Requirements cases and more on FLexlaw
SALCINES, Judge.
Accela, Inc., and CRW Systems, Inc., d/b/a CRW Associates, appeal the final summary judgment entered in favor of defendants, Sarasota County and CSDC Systems, Inc. The trial court determined that Accela and CRW lacked standing to proceed. We reverse. Accela and CRW were plaintiffs below who asserted that the County had improperly awarded contracts to CSDC Systems for computer software and maintenance services without first obtaining competitive bids or proposals. They alleged that the Sarasota County Procurement Code requires such competitive bidding. However, they acknowledged that the Code contains an exception to the requirement for competitive bidding. The plaintiffs complained that they stood ready, willing, and able to submit a competitive bid or proposal had the County invited such bids or proposals. They further assert that even if the exception to the competitive bidding is valid, the County did not abide by the Code’s requirements for the use of that exception.
After the hearing on the motions for summary judgment filed by the County and CSDC, the trial court entered an order granting the motions. It concluded, “The Plaintiffs just don’t have standing.” The summary judgment order was erroneous because “[sjtanding depends on whether a party has a sufficient stake in a justiciable controversy, with a legally cognizable interest which would be affected by the outcome of the litigation.” See Nedeau v. Gallagher, 851 So. 2d 214, 215-16 (Fla. 1st DCA 2003). In the present case, the plaintiffs had standing to complain because they were potential competitors who had a right to seek a determination of whether competitive bidding was required. See, e.g., Randall Indus., Inc. v. Lee County, 307 So. 2d 499, 501 (Fla. 2d DCA 1975). Therefore, we reverse the final summary judgment and remand for further proceedings.
In this appeal, the parties also present arguments directed to language in the trial court’s order that appears to address the merits of plaintiffs’ claims. We decline to address those arguments because standing was the only issue before the trial court and the .trial court was without authority to consider the merits of plaintiffs’ claims after it determined that the plaintiffs lacked standing.
Reversed and remanded for further proceedings.
FULMER and SILBERMAN, JJ., Concur.
Cases With Similar Vibessemantic neighbors from the corpus
Citator
Cited By
-
Francine Liebman v. THE City OF Miami (Fla. 3d DCA 2019)…01 Watson Island RFP, when Flagstone was selected.” pertaining to events that only might occur at some uncertain time in the future, do not create the necessary standing for declaratory or injunctive relief”); with Accela, Inc. v. Sarasota Cty., 901 So. 2d 237, 238 (Fla. 2d DCA 2005) (finding standing where “[t]he plaintiffs complained they stood ready, willing, and able to submit a competitive bid or proposal had the County invited such bids or proposals”); and Matheson, 258 So. 3d at 520 (noting: “Mathe…
-
Matheson v. Miami-Dade Cnty., 258 So. 3d 516 (Fla. 3d DCA 2018)…Matheson alleged that he was “ready, willing and able to purchase the County Property at the same price and on the same terms the County” offered to Miami Properties. This allegation, as it was in Accela, Inc. v. Sarasota County, ---PAGE 6--- 901 So. 2d 237 (Fla. 2d DCA 2005), is sufficient for standing purposes. In that case, as here, the plaintiffs “asserted that the County had improperly awarded contracts to CSDC Systems for computer software and maintenance services without first obtaining comp…
-
Gladding v. Hill (Fla. 2d DCA 2023)…ected by the outcome of the litigation." Whitburn, LLC v. Wells Fargo Bank, N.A., 190 So. 3d 1087, 1091 (Fla. 2d DCA 2015) (quoting Centerstate Bank Cent. Fla., N.A. v. Krause, 87 So. 3d 25, 28 (Fla. 5th DCA 2012)); Accela, Inc. v. Sarasota County, 901 So. 2d 237, 238 (Fla. 2d DCA 2005) ("[S]tanding depends on whether a party has a sufficient stake in a justiciable controversy, with a legally cognizable interest which would be affected by the outcome of the litigation." (quoting Nedeau v. Gallagher, 851 So.…
Authorities Cited
- Randall Indus., Inc. v. LEE Cnty., 307 So. 2d 499 (Fla. 2d DCA 1975)
- Nedeau v. Gallagher, 851 So. 2d 214 (Fla. 1st DCA 2003)