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3rd DCAAugust 14, 2026Pro Se Filing Bar Imposed as Sanction⭐ Notable

Lance Lavallee, et al. v. Andre McIntosh, et al.

Case No. 2026-1542

Exercising its inherent authority to police abuse of the judicial process, the Third District barred a pro se appellant from making any further filings in his appeal from a default final judgment of possession and directed the clerk to refuse any paper not reviewed and signed by a licensed Florida attorney. The sanction followed more than sixty filings in under a month, an explicit prior warning, and a show cause order to which the appellant responded only by repeating previously rejected arguments.

Key facts

  • The trial court entered a Default Final Judgment of Possession against Lance Lavallee on July 16, 2026, and Lavallee filed a notice of appeal the following day.
  • In under one month, Lavallee filed more than sixty documents in the appeal, including roughly thirty motions, most seeking a stay of the writ of possession or a stay of its enforcement; each was denied and each denial was followed by a virtually identical successive motion.
  • +2 more key facts with a free trial

Holdings

  • A district court of appeal possesses inherent authority to determine whether a pro se litigant is abusing the judicial process and, upon a finding of abuse following notice and an…
  • +1 more holding with a free trial

Why it matters

This order is a practical template for parties facing serial frivolous filings in an appellate proceeding, particularly in fast-moving possession and eviction appeals where repetitive stay motions can effectively delay… — full analysis with a trial

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