Daniel Miguel v. In re: Sonia Miguel, etc.

Summary

The Third District Court of Appeal of Florida reversed a guardianship-court order imposing attorney’s fees and expert-witness costs as sanctions against Daniel Miguel. The court held that, before imposing an inherent-authority bad-faith sanction, the trial court was required to conduct an evidentiary hearing providing notice and an opportunity to present witnesses and other evidence. The case was remanded for further proceedings.

Holdings

1. Before imposing an attorney's-fee sanction under its inherent authority for alleged bad-faith conduct, a trial court must provide notice and conduct an evidentiary hearing that affords the accused party and counsel an opportunity to present witnesses and other evidence.
2. The due-process obligation governing inherent-authority sanctions applies to probate and guardianship proceedings.

Questions Presented

1. Whether a guardianship court may impose attorney's-fee sanctions under its inherent authority for alleged bad-faith litigation conduct without first providing notice of and conducting an evidentiary hearing.
2. Whether due process requirements governing inherent-authority sanctions apply in guardianship proceedings.

Disposition

reversed_and_remanded