FRANK A. TESTA, PETITIONER,
v.
LAURA TESTA, RESPONDENT
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The former husband seeks certiorari review of a trial court order that barred him from further pro se filing in this 2008 post-dissolution family law case. We grant-the petition and quash the order because the trial court did not issue an order to show cause and did not provide notice and an *245opportunity to respond before imposing the sanction. Bolton v. SE Prop. Holdings, LLC, 127 So.3d 746 (Fla. 1st DCA 2013); Delgado v. Hearn, 805 So.2d 1017 (Fla. 2d DCA 2001); see also State v. Spencer, 751 So.2d 47 (Fla.1999).
On remand, the trial court shall issue an order to show cause and afford the former husband a reasonable time to respond before determining whether the sanction is appropriate.
Petition granted and order quashed.
LEVINE, CONNER and KLINGENSMITH, JJ., concur.
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Testa v. Dep't OF Revenue o/b/o Laura Testa, 186 So. 3d 614 (Fla. 4th DCA 2016)…of certiorari. We granted the father’s petition and quashed the order, with directions to issue an order to show cause and afford the father a réasonable time to' respond before determining whether the sanction is [*615] appropriate. Testa v. Testa, 171 So. 3d 244, 244-45 (Fla. 4th -DCA 2015). Affirmed. TAYLOR, DAMOORGIAN and GERBER, JJ., concur.…
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Preudhomme v. Garth Bailey & Muschamp LLC, 204 So. 3d 91 (Fla. 4th DCA 2016)…ffirm as to all other aspects of the order. Based on our review of the record, the trial court imposed that sanction prohibiting the pro se appearance without providing the former wife with notice and an opportunity to respond. See Testa v. Testa, 171 So. 3d 244, 244-45 (Fla. 4th DCA [*92] 2015); see also Delgado v. Hearn, 805 So. 2d 1017, 1018 (Fla. 2d DCA 2001) (“While it is clear that a litigant’s right to access the courts may be restricted upon a showing of egregious abuse of the judicial process, ...…
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Steinberg v. Cudak, 429 So. 3d 21 (Fla. 4th DCA 2026)…vide notice and an opportunity to be heard by issuing an order to show cause before prohibiting pro se filing. See Amatulah v. Palmier, 417 So. 3d 495, 496 (Fla. 3d DCA 2025); Humes v. Solanki, 305 So. 3d 334, 336 (Fla. 3d DCA 2020); Testa v. Testa, 171 So. 3d 244, 244–45 (Fla. 4th DCA 2015); Bolton v. SE Prop. Holdings, LLC, 127 So. 3d 746, 747–48 (Fla. 1st DCA 2013); Jackson v. Parkhouse, 826 So. 2d 478, 480 (Fla. 1st DCA 2002); Delgado v. Hearn, 805 So. 2d 1017, 1018 (Fla. 2d DCA 2001). These cases recogni…
Authorities Cited
- State v. Spencer, 751 So. 2d 47 (Fla. 1999)
- Zenen D. Delgado v. Tama P. Hearn, 805 So. 2d 1017 (Fla. 2d DCA 2001)
- Bolton v. SE Prop. Holdings, LLC, 127 So. 3d 746 (Fla. 1st DCA 2013)