Jean-Philippe Schneider v. Christian Tirikian, 3D2023-2272

Schneider, acting pro se and residing in France, was sued by Appellees in 2016 over a business dispute; he filed an answer and counterclaims.
The matter went through extended litigation and was placed on the trial docket multiple times.
On April 21, 2022, the trial court entered an order at 11:41 A.M. resetting the trial and scheduled a calendar call for that same day at 1:00 P.M., providing just 1 hour and 19 minutes' notice.
Schneider did not appear at the calendar call. Appellees orally moved for default, and the trial court granted default against Schneider, dismissing his counterclaims.
Schneider moved to vacate the default, alleging insufficient notice and a violation of due process. The trial court denied the motion, ultimately entering judgment for Appellees after a damages trial.
On appeal, Schneider argued that inadequate notice of the calendar call and the default constituted a violation of his due process rights.

Issue	Plaintiff's Argument	Defendant's Argument	Held
Adequacy of notice for calendar call and default	Schneider received insufficient notice, violating due process	Appellees argued Schneider failed to preserve the argument and default was proper	Insufficient notice; violation of due process. Judgment reversed and remanded.

Mullane v. Central Hanover Bank & Trust Co., 339 U.S. 306 (reasonable notice must be given to affected parties)
Fuentes v. Shevin, 407 U.S. 67 (notice must occur before deprivation is final)
Armstrong v. Manzo, 380 U.S. 545 (due process requires notice reasonably calculated under circumstances)
Zeigler v. Huston, 626 So. 2d 1046 (Fla. 4th DCA 1993) (default entry without notice is error)
Baldwin v. Hale, 68 U.S. 223 (parties must receive notice and an opportunity to be heard)