MARIA NAVARRO MARTIN
v.
STATE OF FLORIDA
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An order barring a litigant from filing future pro se motions does not violate due process when the litigant received notice and an opportunity to respond via an order to show cause.
[1] An order to show cause provides sufficient notice and opportunity to be heard to satisfy due process requirements in proceedings to restrict a litigant's right to file pr…
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Join FLexlaw to unlock all legal intelligenceMaria Navarro Martin appealed multiple orders from the trial court, including an order barring all future pro se filings. Only one order was timely ap…
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SIXTH DISTRICT COURT OF APPEAL
STATE OF FLORIDA
Case No. 6D2024-2218 Lower Tribunal No. 2017-CF-010498-A-O
MARIA NAVARRO MARTIN, Appellant,
V.
STATE OF FLORIDA, Appellee.
Appeal from the Circuit Court for Orange County. Chad K. Alvaro, Judge.
July 10, 2026
WOZNIAK, J.
Maria Navarro Martin seeks to appeal several orders; however, her appeal is timely as to only one of them—the trial court's order barring all future pro se filings. We find no merit in the arguments Martin raises on appeal directed to that order. See State v. Spencer, 751 So. 2d 47, 48-49 (Fla. 1999) (recognizing that issuance of order to show cause satisfies litigant's due process rights of notice and opportunity to respond). Accordingly, we dismiss the appeal insofar as it is untimely, and we affirm the trial court's order barring future pro se filings.
AFFIRMED in part; DISMISSED in part.
GANNAM and PRATT, JJ., concur.
Maria Navarro Martin, Pompano Beach, pro se.
James Uthmeier, Attorney General, Tallahassee, and Whitney Brown Hartless, Assistant Attorney General, Daytona Beach, for Appellee.
NOT FINAL UNTIL TIME EXPIRES TO FILE MOTION FOR REHEARING
AND DISPOSITION THEREOF IF TIMELY FILED
2