Adams v. Adams
The Third DCA affirmed an order declaring a pro se plaintiff a vexatious litigant under section 68.093 and imposing both statutory sanctions and non-statutory sanctions under the trial court's inherent authority — barring her from continuing to represent herself in pending Eleventh Circuit actions and directing the clerk to deactivate her e-filing privileges. The court also held that no separate show cause order was required because the opposing party's motion expressly requested inherent-authority sanctions by title and body, the litigant responded, and a noticed hearing was held.
Key facts
- Pro se plaintiff Adams filed multiple lawsuits and was subject to a motion for sanctions under the vexatious litigant statute and for non-statutory inherent-authority sanctions.
- The trial court declared Adams a vexatious litigant under section 68.093, imposed statutory sanctions, and exercised inherent authority to bar her from appearing pro se in pending Eleventh Circuit actions and to deactivate her e-filing privileges.
- +2 more key facts with a free trial
Why it matters
This is a useful roadmap for practitioners seeking to shut down abusive pro se litigants: it confirms that inherent-authority sanctions can go beyond section 68.093 to include deactivating e-filing portal privileges and… — full analysis with a trial
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