Florida Appeals Court Bars Pro Se Filings and Imposes Sanctions

FL District Court of Appeal Opinions

Filed March 6th, 2026

Detected March 7th, 2026

Summary

The Florida Fifth District Court of Appeal has prohibited Lamar Jay Fullmer from making any further pro se filings concerning a specific past case due to abuse of the legal process. The court directed the Clerk of Court not to accept any future pro se filings from Fullmer for that case and to forward the opinion for consideration of disciplinary proceedings.

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What changed

The Florida Fifth District Court of Appeal has issued an order barring Lamar Jay Fullmer from filing any further pro se (self-represented) legal documents related to Brevard County Circuit Court Case No. 1999-CF-37438. This action stems from the court's determination that Fullmer has abused the judicial process through repetitive, malicious, or frivolous filings. The court's order directs the Clerk of Court to reject any future pro se filings from Fullmer concerning this case, unless they are filed by a licensed attorney.

This ruling has significant implications for Fullmer, who is now prohibited from representing himself in this specific matter. The court also ordered that a certified copy of the opinion be forwarded for consideration of disciplinary proceedings, indicating potential further consequences. For legal professionals, this serves as a strong reminder of the courts' power to sanction abusive litigation tactics and the importance of adhering to procedural rules to avoid such sanctions.

What to do next

Review court orders regarding pro se litigants and potential sanctions for abuse of process.
Ensure all filings are made by licensed attorneys in good standing when required by court order.
Forward relevant court opinions to disciplinary counsel for review if they involve potential attorney misconduct.

Penalties

Prohibition from filing any further pro se filings concerning Brevard County Circuit Court Case No. 1999-CF-37438. Clerk of Court directed not to accept any further pro se filings for this case. Opinion to be forwarded for consideration of disciplinary proceedings.

Source document (simplified)

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March 6, 2026 Get Citation Alerts Download PDF Add Note

Lamar Jay Fullmer v. State of Florida

District Court of Appeal of Florida

Citations: None known
Docket Number: 5D2025-2009
Disposition: Affirmed
Opinion
Authorities (3)
Cited By (0)
Summaries (0)
Similar Cases (0)
PDF

Disposition

Affirmed

Combined Opinion

FIFTH DISTRICT COURT OF APPEAL
STATE OF FLORIDA

Case No. 5D2025-2009
LT Case No. 05-1999-CF-037438-A

LAMAR JAY FULLMER,

Appellant,

STATE OF FLORIDA,

Appellee.

3.800 Appeal from the Circuit Court for Brevard County.
Michelle L. Naberhaus, Judge.

Lamar Jay Fullmer, Okeechobee, pro se.

No Appearance for Appellee.

March 6, 2026

SOUD, J.

Due to Appellant’s apparent abuse of the legal process by his
abusive, repetitive, malicious, or frivolous pro se filings attacking
his judgment and sentence in Brevard County Circuit Court Case
No. 1999-CF-37438, this Court issued an order directing Appellant
to show cause why he should not be prohibited from future pro se
filings. See State v. Spencer, 751 So. 2d 47, 48 (Fla. 1999). Having
carefully considered the response and finding it fails to show cause
why sanctions should not be imposed, we conclude that Appellant
is abusing the judicial process and should be barred from further
pro se filings.

In order to conserve judicial resources, Appellant is prohibited
from filing with this Court any further pro se filings concerning
Brevard County Circuit Court Case No. 1999-CF-37438. The Clerk
of this Court is directed not to accept any further pro se filings
concerning the referenced case. The Clerk will summarily reject
any future filings regarding the referenced case unless filed by a
member in good standing of The Florida Bar. See Isley v. State, 652
So. 2d 409, 411 (Fla. 5th DCA 1995) (“Enough is enough.”). The
Clerk is further directed to forward a certified copy of this opinion
to the appropriate institution for consideration of disciplinary
proceedings. See § 944.279(1), Fla. Stat. (2025); Simpkins v. State,
909 So. 2d 427, 428 (Fla. 5th DCA 2005).

APPELLANT PROHIBITED.

LAMBERT and EISNAUGLE, JJ., concur.