MANDY LEIGH, ESQ.
v.
GUARDIANSHIP OF NORMAN LEIGH, ET AL.

Fla. 4th DCA | 2026-03-18
No. 2024-3184
2026 FL 2833 Florida District Court of Appeal, Fourth District (2026) Positive Treatment

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Holding

Sanctions imposed without notice and opportunity to be heard, and without competent substantial evidence to support them, must be reversed.


Key Quotes

“reversing sanctions where there 'was no hint that any sanctions were contemplated or were to be imposed'”

Citation to Celebrity Cruises, Inc. v. Fernandes, 149 So. 3d 744, 749 (Fla. 3d DCA 2014)

Facts & Procedural History

Norman Leigh and his counsel Mandy Leigh appealed a circuit court order imposing sanctions.…

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Opinion of the Court

PER CURIAM.

Norman Leigh and his counsel, Mandy Leigh, appeal from the circuit court's order imposing sanctions. We reverse because the circuit court issued the sanctions order without notice or the opportunity to be heard. See Celebrity Cruises, Inc. v. Fernandes, 149 So. 3d 744, 749 (Fla. 3d DCA 2014) (reversing sanctions where there “was no hint that any sanctions were contemplated or were to be imposed"). Further, at the time the sanctions order was rendered, no competent substantial evidence supported imposing sanctions.

Reversed.

KUNTZ, C.J., GROSS and GERBER, JJ., concur.


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