Abboud v. Abboud — Court strikes untimely rehearing motion and bars further pro se filings

Case
Camille A. Abboud v. Iryna R. Abboud
Court
Florida Fifth District Court of Appeal
Judge
WALLIS, J. (Rick Scott, 2013); JAY, C.J. (Ron DeSantis, 2023); Harris, J. (appointment info not available)
Date Decided
August 14, 2026
Docket No.
5D2025-2557
Topics
Appellate procedure; Pro se litigation; Sanctions
Source
Read the full opinion

Background

Camille A. Abboud sought certiorari review arising from a St. Johns County family-law case. The Fifth District had previously dismissed his certiorari petition.

On June 26, 2026, the court warned Abboud that his pro se filings concerning the underlying case had become abusive, repetitive, malicious, frivolous, and an abuse of process. It cautioned that further filings raising the same claim could result in Spencer sanctions.

The Court’s Holding

The court struck Abboud’s pending rehearing motion. It held that the motion, filed July 10 after the court’s prior dismissal order, was untimely and continued his abuse of the court’s process.

To conserve judicial resources, the court prohibited Abboud from making any further pro se filings in the Fifth District concerning St. Johns County Case No. 2021-DR-1577. The clerk must summarily reject further filings about that case unless they are filed by a Florida Bar member in good standing.

Key Takeaways

  • An untimely rehearing motion may be stricken rather than considered on the merits.
  • Repeated abusive pro se filings can justify a case-specific filing prohibition.
  • A represented litigant may still file through a Florida Bar member in good standing.

Why It Matters

The decision illustrates the Fifth District’s use of filing restrictions to address repetitive and abusive litigation after a litigant has received an express warning. The restriction is limited to filings concerning the identified underlying case and does not bar filings through counsel.

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