In Save the Homosassa River Alliance, Inc. v. Citrus County, Florida, the Fifth District Court of Appeal broadened the scope of citizens’ standing to challenge whether development decisions are consistent with a local government’s comprehensive plan. In defining the meaning of an aggrieved or adversely affected party under Section 163.3215(2) of the Florida Statutes, the court held that plaintiffs need only allege a particularized interest, and not a particularized harm, in order to satisfy the statutory requirement that their grievance exceeds in degree the general interest in community good shared by all persons. Thus, the court held that an environmental group and its individual members who “demonstrated concern for the protection of the interests furthered by the comprehensive plan” had standing under Section 163.3215(2).

Johnnie is a registered sex offender. When he was eleven he touched his four-year-old half-sister’s vagina (over her underwear). A few months later, she performed oral sex on him at his request. Johnnie’s mother found out. She called the police and Johnnie spent sixteen months in a residential juvenile sex offender program, where he successfully completed treatment. When he was released, Johnnie’s mother wanted nothing to do with him, so he ended up living with his grandmother. Two months after he started at a new middle school, someone found Johnnie on the state’s Internet sex offender registry. Two days later, Johnnie walked into oncoming traffic and told a police officer he wanted to die. He transferred to an alternative school for juvenile delinquents. Even there, the harassment continued. Some of the other boys confronted Johnnie on the school bus, calling him a sex offender and yelling: “You tried to rape your sister!” As a result of anger and depression, Johnnie has twice been admitted to psychiatric hospitals. Not only is Johnnie suicidal, but when he transferred to yet another school and the harassment continued, he told a counselor that he wanted to kill another student for taunting him. Johnnie knows what he did to his sister was wrong and continues to feel guilty about it. Johnnie has never committed another sex offense. Nevertheless, his name,
photo, address, and school information continue to appear on the Internet registry, where they will likely remain for the rest of his life.

There is nothing like a sex scandal to grab people’s attention. In January 2008, the Detroit Free Press published sexually graphic text messages exchanged by Detroit Mayor Kwame Kilpatrick and his then chief of staff Christine Beatty, both of whom had vehemently denied that they were having an extramarital affair. The published messages revealed that Kilpatrick and Beatty lied under oath in a whistleblowers’ lawsuit and that Kilpatrick agreed to settle the suit for $8.4 million to keep the affair quiet. These revelations led to criminal charges that forced Kilpatrick to resign as mayor, give up his law license, pay restitution, and ultimately serve jail and probation time.