KATHLEEN M. BONCZYK
v.
RICHARD C. WOLFE

Fla. 3d DCA | 2026-09-16
No. 2026-1497
Logue, J., Gooden, J., Rebull, J.
2026 FL 12055 Florida District Court of Appeal, Third District (2026)

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Holding

A court may prohibit a pro se litigant from filing further documents without attorney representation when the litigant abuses the judicial process through repeated meritless appeals and petitions.


Headnotes

[1] A court possesses inherent authority to prohibit a pro se litigant from filing further documents without attorney representation when the litigant demonstrates a pattern…

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Key Quotes

“Absent a showing of good cause, the Clerk of the Third District Court of Appeal will be directed to refuse any filing unless it has been reviewed and signed by an attorney who is a duly licensed member of The Florida Bar in good standing.”

Court's warning to Bonczyk citing State v. Spencer, 751 So. 2d 47 (Fla. 1999)

Facts & Procedural History

Bonczyk, a licensed attorney, made false reports against attorney Wolfe in 2021 claiming sexual exploitation based on a law firm photo. After losing a…

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Opinion of the Court

Third District Court of Appeal State of Florida

Opinion filed September 16, 2026. Not final until disposition of timely filed motion for rehearing.

No. 3D26-1497 Lower Tribunal No. 22-663-CA-01

Kathleen M. Bonczyk, Petitioner,

vs.

Richard C. Wolfe, Respondent.

A Case of Original Jurisdiction – Prohibition.

Kathleen M. Bonczyk, in proper person. Richard C. Wolfe, in proper person.

Before LOGUE, GOODEN and REBULL, JJ.

ON ORDER TO SHOW CAUSE

PER CURIAM.

In 2018, Kathleen M. Bonczyk initiated a state action in which Richard C. Wolfe, Esq. represented some of the defendants. That matter was settled in 2020. Thereafter, in December 2021, Bonczyk made several false reports against Wolfe to different government agencies. In short, Bonczyk falsely claimed that Wolfe was involved in the sexual exploitation of his paralegal's thirteen-year-old daughter. Those claims were based solely on Wolfe's law firm posting a photo of his paralegal's daughter during her single-day visit to the law firm over summer break.

Wolfe filed suit against Bonczyk for defamation and defamation per se. Bonczyk, also an attorney, proceeded pro se.1 Final judgment was entered against Bonczyk in September 2025. Throughout the pendency of that matter, and to date, Bonczyk has filed a litany of appeals and petitions pro se before this Court. None have succeeded.2

In the present matter, on July 28, 2026, Bonczyk was ordered to show cause as to why she should not be prohibited from submitting any further pro se filings with this Court.3 Spencer, 751 So. 2d 47 (Fla. 1999),

this Court warned her that “[a]bsent a showing of good cause, the Clerk of the Third District Court of Appeal will be directed to refuse any filing unless it has been reviewed and signed by an attorney who is a duly licensed member of The Florida Bar in good standing.”

After this Court issued its order, Bonczyk proceeded to file eleven different notices and motions, all of which were denied.

Two days after the deadline to respond to the Court's order to show cause, Bonczyk filed her response. We accept this untimely filing. Upon careful review of Bonczyk's response, we conclude that she has failed to show good cause as to why she should not be prohibited from continuing to represent herself in this appeal.

Exercising this Court's inherent authority to determine whether a pro se litigant is abusing the judicial process, we now prohibit Bonczyk from filing any further pro se motions, pleadings, petitions, notices, or any filings with this Court, and require that any such filings be made by an attorney licensed to practice law in Florida. See Jimenez v. State, 196 So. 3d 499, 501 (Fla. 3d DCA 2016); see also Brown v. Miami-Dade Cnty., 319 So. 3d 81, 84 (Fla. 3d DCA 2021) (affirming the county court's determination of an appellant's vexatious litigant status where the county's motion properly set forth “five or more civil actions' which had been ‘commenced, prosecuted or maintained

pro se' by [the appellant] 'over the immediately preceding 5-year period[.]” (quoting § 68.093(2)(d)1., Fla. Stat. (2019))); Hasanati v. State, 117 So. 3d 1157, 1158 n.1 (Fla. 3d DCA 2013) (finding that the appellant “abused the judicial process through his repeated and meritless pro se appeals and petitions" when he filed “[i]n less than three years a total of seventeen separate pro se appeals or petitions,” warranting a ban on further pro se filings).

We direct the Clerk of the Third District Court of Appeal to refuse to accept any such papers unless they have been reviewed and signed by an attorney who is a duly licensed member of The Florida Bar in good standing. Since Bonczyk is a licensed attorney, we have also sent a copy of this order to the Florida Bar for referral.

This order shall take effect immediately. No motions for rehearing shall be entertained.

So ordered.

Footnotes
1 See Case No. 2022-000663-CA-01. 2 See Case Nos. 3D2023-0369; 3D2023-1146; 3D2023-2269; 3D2024-2080; 3D2025-0211; 3D2025-0309; 3D2025-0506; 3D2025-2044; 3D2025-2173; 3D2025-2388; 2026-0511; 3D2026-0761; 3D2026-1259. 3 Bonczyk was deemed a vexatious litigant below. See Case No. 2022- 000663-CA-01 Docket Entry 1461.
3 Citing State v.

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