A trial court may declare a party a vexatious litigant under section 68.093 and impose sanctions under both the statute and its inherent authority, so long as the litigant gets due process. The Third District Court of Appeal affirmed such an order, entered even after the plaintiff voluntarily dismissed her suit.
Michelle Adams, appearing pro se, was declared a vexatious litigant on her opponent’s motion. She responded to the motion and was given a hearing — which she refused to attend despite proper notice. The trial court then entered the order and sanctions, relying on the Vexatious Litigant Law and its inherent power.
The panel held the court had jurisdiction to act notwithstanding the earlier voluntary dismissal, and that Adams received due process: notice and an opportunity to be heard, which she declined to use. It affirmed both the vexatious-litigant determination and the additional, non-statutory sanctions.
**Why it matters:** the Vexatious Litigant Law and a court’s inherent authority give real tools against abusive serial filers, and a party can’t defeat them by dismissing the case or by skipping a properly noticed hearing.
*Adams v. Adams, No. 3D26-0921 (Fla. 3d DCA Sept. 2, 2026).*