Cotara Christina Farrington v. Julson Nicolas
The Third District granted certiorari and quashed a trial court order that sua sponte limited a pro se litigant's future filings and emails to the court. Because an order restricting a litigant's filing conduct is in essence a sanction, entering it without a pending motion directed to the right being restricted, notice, and an opportunity to be heard departed from the essential requirements of law. The complete denial of due process constituted irreparable harm reviewable by certiorari.
Key facts
- Cotara Christina Farrington was proceeding pro se in a Miami-Dade custody matter before Judge Scott M. Bernstein.
- On June 12, 2026, the trial court entered, sua sponte, an 'Order Limiting Petitioner's Litigation Conduct' restricting Farrington's future filings and emails to the court.
- +2 more key facts with a free trial
Holdings
- An order limiting or restricting a litigant's future filings and emails to the court is, in essence, a sanction, and a trial court violates due process when it imposes sanctions sua sponte…
- +1 more holding with a free trial
Why it matters
Useful in any civil case, not just family court. Trial judges increasingly enter filing-limitation or 'litigation conduct' orders to manage difficult litigants, and this opinion holds that such orders are sanctions… — full analysis with a trial
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