Johnson v. Rundle
59 So. 3d 1080
| Fla. | 2011Background
- Johnson, an inmate, sought extraordinary relief from a 1998 armed-robbery conviction and life sentence in F97-32329.
- Two petitions were consolidated: SC10-35 (quo warranto) and SC10-207 (habeas corpus).
- The Florida Supreme Court denied the petitions on April 22, 2010, and retained jurisdiction to sanction abusive filings.
- The Court had previously directed Johnson to show cause why he should not be barred from filing further pleadings unless signed by a member of The Florida Bar.
- Johnson submitted responses claiming his filings were meritorious and that the Court was the proper forum for redress.
- The Court concluded Johnson repeatedly initiated frivolous proceedings and imposed a sanction prohibiting unbarred pro se filings relating to case 97-32329.
Issues
| Issue | Plaintiff's Argument | Defendant's Argument | Held |
|---|---|---|---|
| Whether the Court had inherent authority to sanction abusive litigants. | Johnson contends the sanction is improper. | The Court has inherent power to curb abusive filings. | Yes, Court has inherent authority. |
| Whether barring pro se filings unless signed by a Florida Bar member is appropriate. | Johnson argues against prohibiting access to the Court. | Sanction ensures access for meritorious claims by others. | Yes, sanction approved. |
| Whether the sanction is narrowly tailored to Johnson’s conduct and case. | Johnson claims overbreadth and punishment beyond merits. | Sanction targeted to frivolous filings linked to 97-32329. | Yes, tailored to abusive filings. |
Key Cases Cited
- Sibley v. Fla. Jud. Qual. Comm'n, 973 So.2d 425 (Fla. 2006) (inherent authority to sanction abusive litigants)
- Pettway v. McNeil, 987 So.2d 20 (Fla. 2008) (support for sanctioning abusive filings to protect court resources)
- Lanier v. State, 982 So.2d 626 (Fla. 2008) (illustrates concern about nonmeritorious requests)
- Tate v. McNeil, 983 So.2d 502 (Fla. 2008) (courts may sanction frivolous filings)
- Jackson v. Fla. Dept. of Corrections, 790 So.2d 398 (Fla. 2001) (relevant to frivolous and abusive litigation patterns)
- Attwood v. Singletary, 661 So.2d 1216 (Fla. 1995) (free access to courts balanced against abuse)