Steinberg v. Cudak
A pro se HOA member appealed an order declaring him a vexatious litigant under section 68.093, requiring $50,000 security, and directing the clerk to reject any future filings not signed by a Florida Bar member. The Fourth DCA affirmed the vexatious-litigant determination and held the trial court retained jurisdiction to impose sanctions despite a notice of voluntary dismissal, but reversed the pro se filing bar because the court imposed that inherent-authority sanction without first issuing a Spencer order to show cause.
Key facts
- Pro se HOA member Steinberg appealed a trial court order designating him a vexatious litigant under section 68.093, imposing a $50,000 security requirement, and barring him from filing future cases without a Florida Bar member's signature.
- The trial court issued the vexatious-litigant designation and sanctions after Steinberg filed a notice of voluntary dismissal of the underlying HOA dispute, without first issuing a show-cause order before imposing the pro se filing bar.
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Why it matters
Practitioners defending or seeking vexatious-litigant sanctions get a clean roadmap: the statutory security remedy and the court's inherent authority to bar pro se filings are distinct, and the latter requires a Spencer… — full analysis with a trial
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