There is a vast, and sometimes arcane, body of case law on who is an aggrieved party. Generally speaking, a party is aggrieved when he does not prevail, as when an order or judgment is entered against him, or his motion for affirmative relief is denied.
Can an attorney representing a party be aggrieved? The question arises, for example, when an attorney moves to have a court sanction opposing counsel for frivolous or improper conduct during the litigation. Suppose the judge denies the motion to sanction the attorney but in the course of his opinion he makes comments critical of the attorney. Can the attorney appeal the order which did not sanction him because he objects that the judge's critical comments are unjustified?
Today in Keach v. County of Schenectady the United States Court of Appeals for the Second Circuit concludes that the criticized but unsanctioned attorney is not an aggrieved party and, therefore, the appellate court has no jurisdiction to hear his appeal. The opinion can be found here.
For an attorney to be aggrieved for purposes of appeal, says the Second Circuit, the attorney must have suffered an adverse decision. Critical words alone are not reviewable by an appellate court. On the other hand, an attorney is an aggrieved party if he is sanctioned by the court, or the court makes specific findings that the attorney violated a rule of professional conduct, or a court refers the attorney's alleged misconduct to a disciplinary committee. "An appellate court can reverse an order imposing a sanction or making a finding that an attorney has violated a rule of professional conduct; it has no power to reverse a judge's poor opinion of the skill or trustworthiness of a lawyer who has appeared before him or her. "