Florida Department of Corrections v. Holt
The Department of Corrections sought a writ of quo warranto to stop the Thirteenth Circuit Public Defender from representing an inmate in a section 960.293 civil restitution lien proceeding. The Second District held the Department's secretary had standing as a citizen/taxpayer to seek quo warranto enforcing a public right, and on the merits held that civil restitution lien proceedings are civil, do not implicate liberty interests or postconviction due process, and therefore fall outside the public defender's statutory authority under section 27.51.
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