Michelle Adams v. Max Adams
The Third District affirmed an order declaring a pro se plaintiff a vexatious litigant under section 68.093 and imposing both statutory prefiling restrictions and non-statutory sanctions under the court's inherent authority. The court held that deactivating the litigant's Florida Courts E-Filing Portal privileges is a permissible corollary of a valid bar on pro se filings, and that a separate show cause order was unnecessary where the sanctions motion itself, the litigant's written response, and a noticed hearing supplied equivalent due process. Notably, the trial court retained authority to enter the order even after the plaintiff voluntarily dismissed her suit.
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