TERESA GAFFNEY
v.
PHILLIP A. BAUMANN, ETC.

Fla. | 2025-09-11
No. SC2024-1862
2025 FL 7915 Florida Supreme Court (2025)

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Synopsis

The Florida Supreme Court imposed sanctions on Teresa Gaffney, a pro se litigant, barring her from filing future pleadings in her own name related to two specific Hillsborough County cases without representation by a Florida Bar member. This was the Court's fifth denial of Gaffney's requests for review in the same matter, and the Court determined that her continued filings constituted an abuse of judicial process.


Holding

The Florida Supreme Court concluded that Gaffney's repeated frivolous filings constituted an abuse of judicial process and imposed sanctions prohibiting her from filing any future pleadings, petitions, motions, or other documents related to the two specified cases unless signed by a Florida Bar member in good standing.


Headnotes

[1] A court may sanction a party for abusing the judicial process by filing frivolous or meritless pleadings.

[2] A court may order the clerk to reject future filings from a pro se litigant pertaining to specific circuit court cases if the litigant fails to show cause why they should…

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Key Quotes

“Petitioner has abused the judicial process by filing frivolous filings in this Court related to this matter that are either meritless or not appropriate for this Court's review.”

The Court's rationale for imposing sanctions, establishing that repeated meritless or inappropriate filings constitute judicial abuse.

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Facts & Procedural History

Teresa Gaffney, initially represented by her late husband in earlier filings, has filed at least five petitions for review with the Florida Supreme Co…

The full statement of facts, procedural history, and disposition for this case are member content.

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Opinion of the Court

PER CURIAM.

This case is before the Court on the petition of Teresa Gaffney to invoke this Court's discretionary jurisdiction based on express and direct conflict. In our order dated May 14, 2025, we denied the petition for review, retained jurisdiction to pursue any possible sanctions, granted a motion for attorney's fees filed by Respondent Michael R. Kangas, Successive Administrator Ad Litem of the Estate of John J. Gaffney, in the amount of $2,500.00, and directed Petitioner to show cause why she should not be barred from any future pro se filings in this Court related to Hillsborough County

Circuit Court cases 292014CA003762A001HC and 292020CA002115A001HC.

This case represents our fifth denial of a request for review by Petitioner related to this matter. See Case Nos. SC2019-0893, SC2019-0899, SC2021-1212, SC2024-1474, and SC2024-1862. Petitioner's late husband represented her in the first three cases; she has represented herself in the last two cases.

We issued the order to show cause because Petitioner has abused the judicial process by filing frivolous filings in this Court related to this matter that are either meritless or not appropriate for this Court's review. Petitioner has filed a response to the order to show cause.

After considering Petitioner's response, we conclude that it fails to show cause why she should not be sanctioned. Accordingly, the Clerk of this Court is hereby instructed to reject any future pleadings, petitions, motions, documents, or other filings submitted by Teresa Gaffney pertaining to Hillsborough County Circuit Court cases 292014CA003762A001HC and 292020CA002115A001HC, unless such filings are signed by a member in good standing of The Florida Bar. Counsel may file on Gaffney's behalf if counsel

determines that the proceeding may have merit and can be brought in good faith.¹

No motion for rehearing or clarification will be entertained by this Court. See Fla. R. App. P. 9.330(d)(2).

All pending motions are hereby denied as moot.

It is so ordered.

MUÑIZ, C.J., and CANADY, LABARGA, COURIEL, GROSSHANS, FRANCIS, and SASSO, JJ., concur. Application for Review of the Decision of the District Court of Appeal Direct Conflict of Decisions

Second District - Case No. 2D2024-0352 (Hillsborough County)

Teresa M. Gaffney, pro se, Tampa, Florida,

for Petitioner

Michael R. Kangas of BaumannKangas Estate Law, Tampa, Florida,

for Respondent

Footnotes
1 1. In recent years, we have imposed comparable sanctions on other litigants whose pro se filing practices have exhibited their disregard for abusing the scarce judicial resources of this Court. See, e.g., Rivas v. Bank of N.Y. Mellon, 239 So. 3d 614 (Fla. 2018); Fla. Bar v. Petrano, 153 So. 3d 894 (Fla. 2014); Steele v. State, 14 So. 3d 221 (Fla. 2009); Pettway v. McNeil, 987 So. 2d 20 (Fla. 2008); Sibley v. Fla. Jud. Qualifications Comm’n, 973 So. 2d 425 (Fla. 2006).

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