Wright v. JPay — court barred Wright from further pro se filings

Case
Walter L. Wright v. JPay LLC and Ricky D. Dixon, Secretary of the Florida Department of Corrections
Court
Florida Third District Court of Appeal
Judge
Lindsey; Lobree; Gooden
Date Decided
September 2, 2026
Docket No.
3D2026-0806
Topics
Vexatious litigation; Pro se filings; Appellate procedure
Source
Read the full opinion

Background

Walter L. Wright filed a 2022 civil action against the Florida Department of Corrections and JPay LLC. The trial court sent the parties to binding arbitration and dismissed Wright’s complaint with prejudice as to the Department.

Afterward, Wright pursued four unsuccessful appeals and petitions without counsel. The Third District had also previously barred him, in a separate case, from pro se filings related to his convictions, judgments, and sentences. In July 2026, the court ordered Wright to show cause why he should not be prohibited from making further pro se filings in the court.

The Court’s Holding

In a per curiam order, the Third District concluded that Wright had not shown good cause to continue representing himself in this appeal. Exercising its inherent authority to address abuse of the judicial process, the court prohibited him from filing further pro se motions, pleadings, petitions, notices, or other filings in the court.

The clerk must refuse Wright’s filings unless they have been reviewed and signed by an attorney licensed and in good standing with The Florida Bar. The order took effect immediately, and the court stated that it would entertain no rehearing motions.

Key Takeaways

  • A Florida appellate court may restrict a litigant’s pro se filings when repeated meritless filings abuse the judicial process.
  • The restriction applies to all future filings in the Third District, not solely filings concerning this civil action.
  • Wright may file only through a Florida Bar attorney who reviews and signs the submission.

Why It Matters

The order illustrates the Third District’s use of its inherent authority to curb repetitive pro se litigation. It also shows that a filing restriction can be imposed through an order to show cause after a litigant has pursued multiple unsuccessful appeals or petitions.

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