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Moises Rios, Jr. v. Kathryn Hawkins D/B/A Safe Pet Rescue

2026-08-28

Summary

Holding. The appellate court reversed the dismissal and remanded the case for further proceedings, holding that Rios was denied due process when the trial court dismissed his replevin claim without providing him notice or an opportunity to be heard before entry of the dismissal order.

In March 2024, Rios was arrested following a vehicle accident while in possession of his dogs. Law enforcement placed the dogs in a county animal shelter's holding facility, and when the shelter could not contact Rios, it transferred the dogs to Safe Pet Rescue in early April. After learning of the transfer in May, Rios requested the return of his dogs but was informed they had already been adopted. Rios then filed a replevin action to recover possession of the dogs.

The trial court issued an order directing Safe Pet to show cause why the dogs should not be returned to Rios. A hearing on this show cause order was scheduled for July 19, 2024. On that date, the court's unsigned notes indicated the case should be dismissed, though no formal dismissal order was entered at that time. Approximately six months later, after a hearing on a lack-of-prosecution notice, the court entered a written dismissal order dated back to July 19, 2024.

Rios appealed, contending the dismissal violated his due process rights because he received no notice that dismissal would be considered at the show cause hearing and no opportunity to be heard before the dismissal order was entered. The appellate court agreed, finding that the July hearing concerned only the show cause order and contained nothing alerting Rios that the entire action might be dismissed.

Summary generated by law.co from the public-domain opinion. The opinion text itself is public domain.

Key issues

  • Whether dismissal of an action without notice or opportunity to be heard violates due process
  • Whether a show cause hearing can be used as a vehicle for dismissing an entire action when dismissal was not indicated in the order or notice
  • Proper procedural notice required before a trial court enters a dismissal order

Procedural posture

Rios appealed a trial court order of dismissal, nunc pro tunc, of his replevin action filed in county court for St. Johns County.

Authorities cited

No cited authorities resolved to law.co cases yet.

Opinion

majority opinion

FIFTH DISTRICT COURT OF APPEAL

STATE OF FLORIDA

Case No. 5D2025-1928

LT Case No. 55-2024-SC-2869

MOISES RIOS, JR.,

Appellant,

v.

KATHRYN HAWKINS d/b/a SAFE

PET RESCUE,

Appellee.

On appeal from the County Court for St. Johns County. Alexander R. Christine, Jr., Judge.

Jason A. Martorella, of Martorella Law, Coral Gables, for Appellant.

David D. Naples, Jr. and Tiera L. Henry, of D. Naples Law, PLLC, St. Augustine, for Appellee.

August 28, 2026

HARRIS, J.

In March 2024, Appellant, Moises Rios, Jr., was arrested after a vehicle accident, with his dogs in his possession, and was subsequently detained at Lee County and Sumter County Detention Center. Law enforcement transported his dogs to the Lee County animal shelter where they were placed in a five-day holding period. During that period, the animal shelter unsuccessfully attempted to make contact with Appellant. Animal control then transferred possession of the dogs to Appellee, Kathryn Hawkins d/b/a Safe Pet Rescue (“Safe Pet”), around April 9, 2024.

After learning that his dogs were transferred to Safe Pet, Appellant sent Appellee an email on May 6, 2024 seeking to have the dogs returned to him. Appellee informed Appellant that the dogs had already been adopted.

Appellant subsequently filed a pro se statement of claim for replevin against Appellee, seeking to reclaim possession of his dogs. The court entered an order directing Appellee to show cause as to why the property should not be taken from her possession and delivered to Appellant. A hearing on the show cause order was scheduled for July 19, 2024. However, four days before the hearing, Appellee filed an answer and affirmative defenses to Appellant’s claim, alleging Safe Pet lawfully obtained possession and ownership of the dogs from animal control and that it was no longer in possession of the dogs, who were legally adopted to a new home.

On July 19, 2024, a few hours before the scheduled hearing on the show cause order, Appellant filed a motion for continuance. The hearing nevertheless proceeded. While there is no transcript from this hearing in the record, the unsigned court notes indicate that the court was “to dismiss case.”

Six months later, the court filed a notice of lack of prosecution for no record activity, setting a hearing for March 28, 2025. The court notes following that hearing state “case to remain open.” Appellee then filed a motion asking the court to enter a written order dismissing the action in accordance with the court notes from the July 19, 2024 hearing. On May 28, 2025, the court entered an order of dismissal, nunc pro tunc to July 19, 2024.

Appellant argues the trial court violated his right to due process by dismissing his claim without notice, after it had ruled that the case would remain open. He emphasizes that there was no order actually dismissing the case after the July 19, 2024

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hearing, and that the July hearing was not a hearing on a motion to dismiss; rather, it was a hearing on the trial court’s order to show cause. We agree.

Here, the July 19 hearing was for the court’s show cause order directed at Appellee. There was no motion to dismiss or objection pending, nor did the show cause order mention dismissal or closing of the action. See McGhee v. Est. of McGhee, 373 So. 3d 417, 418–19 (Fla. 2d DCA 2023). Based upon the record before this Court, there was nothing that gave Appellant notice or warning that dismissal of the entire action would be considered at the hearing noticed solely on the court’s show cause order. Thus, Appellant was not given an opportunity to be heard prior to entry of the dismissal order.

Accordingly, because Appellant was denied due process before dismissal of his claim, we reverse and remand for further proceedings.

REVERSED and REMANDED for further proceedings.

EISNAUGLE and BOATWRIGHT, JJ., concur.

Not final until disposition of any timely and

authorized motion under Fla. R. App. P. 9.330 or

9.331.

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