JAMES LYONS
v.
LAURA M. STEINER

Fla. 5th DCA | 2023-01-23
No. 22-2071
Florida District Court of Appeal, Fifth District (2023) Positive Treatment
Cited by 1 case

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Holding

A trial court must issue an order to show cause providing a pro se party with reasonable notice and an opportunity to be heard before barring that party from future pro se filings.


Headnotes

[1] Before barring a pro se party from future filings, a trial court must issue an order to show cause that provides the party with reasonable notice and an opportunity to re…

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Key Quotes

“a court must first provide notice and an opportunity to be heard before barring a pro se party from future filings”

Citation to State v. Spencer, 751 So. 2d 47, 48 (Fla. 1999), establishing the required procedure

Facts & Procedural History

James Lyons, appearing pro se in a post-final judgment paternity proceeding, was barred from further pro se filings by the trial court. The trial cour…

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Opinion of the Court

PER CURIAM.

James Lyons petitions this court for the issuance of a writ of certiorari. He contends that the trial court erred when it barred him from further pro se filings in his post-final judgment paternity proceeding without first providing him with notice and an opportunity to be heard before imposing this sanction.1 See State v. Spencer, 751 So. 2d 47, 48 (Fla. 1999) (stating that a court must first provide notice and an opportunity to be heard before barring a pro se party from future filings).

This court has recently granted certiorari relief to a pro se party when the trial court prohibited the litigant from future pro se filings without first complying with the Spencer procedure of issuing an order to show cause providing the litigant with reasonable notice and an opportunity to respond before imposing this sanction. See McCone v. Pitney Bowes, Inc., 342 So. 3d 826, 827 (Fla. 5th DCA 2022). Because the trial court here did not follow this procedure, we grant the petition and quash, without prejudice, that part of the respective orders barring Lyons from pro se filings.2 PETITION GRANTED; ORDERS QUASHED.

LAMBERT, C.J., EVANDER and HARRIS, JJ., concur.

Footnotes
1 Lyons also sought certiorari review of that aspect of one order restricting his timesharing with his minor child. Lyons subsequently withdrew this claim.
2 The trial court may reconsider whether to bar Lyons from future pro se filings; but if it does so, the court must comply with the procedural requirement of issuing an order to show cause that gives Lyons both reasonable notice and an opportunity to be heard. We take no position on the merits of whether Lyons should be barred from future pro se filings below.

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Citator

Cited By

  • Lyons v. Steiner (Fla. 5th DCA 2023)
    …future pro se filings without first complying with the Spencer procedure of issuing an order to show cause providing the litigant with reasonable notice and an opportunity to respond before imposing this sanction. See McCone v. Pitney Bowes, Inc., 342 So. 3d 826, 827 (Fla. 5th DCA 2022). Because the trial court here did not follow this procedure, we grant the petition and quash, without prejudice, that part of the respective orders barring Lyons from pro se filings.2 PETITION GRANTED; ORDERS QUASHED. LAMBE…

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