Solomon D. Roberts v. Julie L. Jones, etc., 213 So. 3d 912

Solomon D. Roberts, serving life sentences for multiple 1982 convictions in Miami‑Dade County, has repeatedly filed pro se postconviction petitions since 2000 (this was his 25th filing to the Florida Supreme Court).
Lower courts (Third DCA and Eleventh Circuit) previously barred him from filing further pro se postconviction motions in state court for these cases.
Roberts filed a habeas petition to the Florida Supreme Court challenging his convictions/sentences and the circuit court’s application of its barring order; the petition was dismissed in part as meritless and in part as unauthorized.
The Court issued a show‑cause order under State v. Spencer directing Roberts to explain why he should not be barred from future pro se filings and referred the matter to the Florida Department of Corrections under section 944.279(1).
Roberts argued his sentence was illegal and claimed manifest injustice, but courts had previously considered and rejected those claims; he offered no indication he would cease filing frivolous pleadings.
The Court concluded the petition was frivolous and imposed a restriction: future filings challenging these convictions/sentences will be rejected unless signed by a member of the Florida Bar; a certified copy of the opinion was sent to the DOC for possible disciplinary action.

Issue	Roberts' Argument	Respondent's Argument	Held
Whether the Court should impose a filing restriction on Roberts' future pro se filings about his convictions/sentences	Roberts: his sentence is illegal and manifests a jurisdictional defect; his continued filings are diligent attempts to correct injustice	Court/State: Roberts has repeatedly filed meritless, unauthorized, and procedurally barred petitions despite prior rulings; judicial resources are being abused	Court: Sanctions appropriate; Clerk to reject future pro se filings on these cases unless signed by a Florida Bar member
Whether the instant habeas petition had merit	Roberts: alleges illegal sentence/manifest injustice	Respondent: prior rulings already addressed these claims; petition is meritless/unauthorized	Court: Petition dismissed in part as meritless and in part as unauthorized
Whether Roberts adequately showed cause why sanctions should not be imposed	Roberts: his pursuit of relief is justified and not sanctionable	Respondent: Roberts offered no reason he would stop abuse; prior denials defeat his claims	Court: Roberts failed to show cause; sanctions upheld
Whether referral to DOC under §944.279(1) was proper	Roberts: not addressed as a substantive defense	Respondent/Court: statute authorizes report of frivolous prisoner litigation to DOC for discipline	Court: Directed Clerk to forward certified opinion to DOC for possible disciplinary action

Pettway v. State, 776 So. 2d 930 (Fla. 2000) (authorizes dismissal of meritless petitions)
Baker v. State, 878 So. 2d 1236 (Fla. 2004) (unauthorized petitions may be dismissed)
State v. Spencer, 751 So. 2d 47 (Fla. 1999) (procedure to show cause and impose filing restrictions on repetitive prisoner filings)
Steele v. State, 14 So. 3d 221 (Fla. 2009) (directing forwarding of opinions to DOC under §944.279)