T. R., FATHER OF J.W., A MINOR CHILD

v.

DEPARTMENT OF CHILDREN AND FAMILIES, ET AL.

Supreme Court of Florida

No. SC2026-0557

T.R., FATHER OF J.W., A MINOR CHILD, Petitioner,

VS.

DEPARTMENT OF CHILDREN AND FAMILIES, et al., Respondents.

September 10, 2026

PER CURIAM.

T.R., a pro se litigant, filed a petition for writ of habeas corpus with this Court.¹ See T.R. v. Dep't of Child. &

1. We have jurisdiction. See art. V, § 3(b)(9), Fla. Const.

Fams., 430 So. 3d 231 (Fla. 5th DCA 2025) (Mem). Petitioner's parental rights were subsequently terminated (“TPR”) in April 2025, followed by full appellate review in the Fifth District, which per curiam affirmed the TPR in October 2025. See T.R. v. Dep't of Child. & Fams., 426 So. 3d 550 (Fla. 5th DCA 2025) (Mem). On December 18, 2025, the circuit court issued an order in case number 102023DP000105DPAXXX, terminating jurisdiction and instructing the clerk to close the case after a final judgment of adoption was entered for the child.

Including the habeas petition in this case, Petitioner has filed 16 pro se extraordinary writ petitions or notices with this Court since 2025, all related to Fourth Judicial Circuit case number 102023DP000105DPAXXX. The Court has never granted the relief sought in any of Petitioner's cases; all petitions or notices to invoke were either denied, dismissed, or transferred.² See T.R. v. Dep't of Child. & Fams., No. SC2026-0850 (Fla. July 20, 2026) (mandamus denied); T.R. v. Clay Cnty. Clerk of Ct., No. SC2026-0533 (Fla. Apr. 9, 2026) (mandamus transferred); T.R. v. Dep't of Child. & Fams., No. SC2026-0421 (Fla. Mar. 30, 2026) (prohibition dismissed); T.R. v. Dep't of Child. & Fams., No. SC2026- 0245 (Fla. Mar. 30, 2026) (habeas dismissed); T.R. v. Dep't of Child. & Fams., No. SC2026-0233 (Fla. Mar. 30, 2026) (mandamus dismissed); T.R. v. Dep't of Child. & Fams., No. SC2026-0208 (Fla.

case is no exception. Petitioner argued that his minor child had been unlawfully restrained due to multiple trial court errors and an incomplete record on appeal. He sought an order vacating the final judgment and authorizing the immediate return of the child to his custody and an immediate stay preventing enforcement of the TPR and the adoption proceedings. On June 8, 2026, we dismissed the habeas petition as moot and expressly retained jurisdiction to pursue possible sanctions against Petitioner. T.R. v. Dep't of Child. & Fams., No. SC2026-0557 (Fla. June 8, 2026); see Fla. R. App. P. 9.410(a) (Sanctions; Court's Motion). We now find that Petitioner has failed to show cause why he should not be barred, and we sanction him as set forth below.

Feb. 13, 2026) (habeas transferred); T.R. v. Dep't of Child. & Fams., No. SC2025-2044 (Fla. Dec. 23, 2025) (notice to invoke dismissed); T.R. v. Dep't of Child. & Fams., No. SC2025-2043 (Fla. Dec. 23, 2025) (notice to invoke dismissed); T.R. v. Dep't of Child. & Fams., No. SC2025-1948 (Fla. Dec. 19, 2025) (mandamus denied); T.R. v. Dep't of Child. & Fams., No. SC2025-1835 (Fla. Dec. 3, 2025) (prohibition denied); T.R. v. Dep't of Child. & Fams., No. SC2025- 1783 (Fla. Nov. 19, 2025) (mandamus denied); T.R. v. Dep't of Child. & Fams., No. SC2025-1712 (Fla. Nov. 3, 2025) (habeas transferred); T.R. v. Dep't of Child. & Fams., No. SC2025-1603 (Fla. Oct. 16, 2025) (prohibition transferred); T.R. v. Dep't of Child. & Fams., No. SC2025-1597 (Fla. Oct. 14, 2025) (mandamus dismissed); T.R. v. Dep't of Child. & Fams., No. SC2025-0233 (Fla. Feb. 18, 2025) (notice to invoke dismissed).

In response to this Court's show cause order, Petitioner repeats much of the argument found in his petition. He insists that his pleadings are justified, disputes that they are frivolous, and based on his assertion that his rights as a biological parent remain intact despite the TPR, indicates that he will persist in challenging the dependency proceedings and the TPR.

"Frivolous” is defined as “[l]acking in high purpose; trifling, trivial, and silly” and “[l]acking a legal basis or legal merit; manifestly insufficient as a matter o[f] law.” Black's Law Dictionary (12th ed. 2024); see also Neitzke v. Williams, 490 U.S. 319, 325 (1989) (stating that a complaint is frivolous “where it lacks an arguable basis either in law or in fact"). Regarding the instant petition, Petitioner's assertion of his right to habeas relief as a biological parent lacks a sufficient basis in law or in fact. This Court has held that “an order of termination of parental rights permanently deprives the parents or legal guardian of any right to the child." Stefanos v. Rivera-Berrios, 673 So. 2d 12, 13 (Fla. 1996) (citing section 39.469, now renumbered section 39.811). Any rights the natural parent may have had regarding the child are permanently forfeited and cannot be reopened by means other than

a proper appeal of the order terminating parental rights. Id. Here, the circuit court's final judgment terminating Petitioner's parental rights was per curiam affirmed by the Fifth District on appeal. Habeas can only be used to obtain custody of a child wrongfully withheld. Here, however, Petitioner's parental rights have been terminated so that he has no right to custody, and no basis for habeas relief. As a result, Petitioner's claims in the present case are frivolous, and his claims in the prior cases before this Court were similarly frivolous.

Upon consideration of Petitioner's response, we find that he has failed to show cause why sanctions should not be imposed. Therefore, based on Petitioner's extensive history of filing pro se petitions and requests for relief that were frivolous or otherwise inappropriate for this Court's review, we now find that he has abused the Court's limited judicial resources. See Pettway v. McNeil, 987 So. 2d 20, 22 (Fla. 2008) (explaining that this Court has previously “exercised the inherent judicial authority to sanction an abusive litigant” and that "[o]ne justification for such a sanction lies in the protection of the rights of others to have the Court

conduct timely reviews of their legitimate filings”). If no action is taken, Petitioner will continue to burden the Court's resources.

Accordingly, we direct the Clerk of this Court to reject any future pleadings or other requests for relief submitted by T.R. that are related to the dependency proceedings, and appeals thereof, in Fourth Judicial Circuit case number 102023DP000105DPAXXX, unless such filings are signed by a member in good standing of The Florida Bar.

No motion for rehearing or clarification will be considered by this Court.

It is so ordered.

COURIEL, C.J., and LABARGA, MUÑIZ, GROSSHANS, FRANCIS, BARRIOS, and TANENBAUM, JJ., concur.