Third District Court of Appeal
State of Florida
Opinion filed September 16, 2026.
Not final until disposition of timely filed motion for rehearing.
No. 3D26-1497
Lower Tribunal No. 22-663-CA-01
Kathleen M. Bonczyk,
Petitioner,
vs.
Richard C. Wolfe,
Respondent.
A Case of Original Jurisdiction – Prohibition.
Kathleen M. Bonczyk, in proper person.
Richard C. Wolfe, in proper person.
Before LOGUE, GOODEN and REBULL, JJ.
ON ORDER TO SHOW CAUSE
PER CURIAM.
In 2018, Kathleen M. Bonczyk initiated a state action in which Richard
C. Wolfe, Esq. represented some of the defendants. That matter was settled
in 2020. Thereafter, in December 2021, Bonczyk made several false reports
against Wolfe to different government agencies. In short, Bonczyk falsely
claimed that Wolfe was involved in the sexual exploitation of his paralegal’s
thirteen-year-old daughter. Those claims were based solely on Wolfe’s law
firm posting a photo of his paralegal’s daughter during her single-day visit to
the law firm over summer break.
Wolfe filed suit against Bonczyk for defamation and defamation per se.
Bonczyk, also an attorney, proceeded pro se.1 Final judgment was entered
against Bonczyk in September 2025. Throughout the pendency of that
matter, and to date, Bonczyk has filed a litany of appeals and petitions pro
se before this Court. None have succeeded. 2
In the present matter, on July 28, 2026, Bonczyk was ordered to show
cause as to why she should not be prohibited from submitting any further pro
se filings with this Court. 3 Citing State v. Spencer, 751 So. 2d 47 (Fla. 1999),
1
See Case No. 2022-000663-CA-01.
2
See Case Nos. 3D2023-0369; 3D2023-1146; 3D2023-2269; 3D2024-2080; 3D2025-0211; 3D2025-0309; 3D2025-0506; 3D2025-2044; 3D2025-2173; 3D2025-2388; 2026-0511; 3D2026-0761; 3D2026-1259.
3
Bonczyk was deemed a vexatious litigant below. See Case No. 2022-000663-CA-01 Docket Entry 1461.
2
this Court warned her that “[a]bsent a showing of good cause, the Clerk of
the Third District Court of Appeal will be directed to refuse any filing unless
it has been reviewed and signed by an attorney who is a duly licensed
member of The Florida Bar in good standing.”
After this Court issued its order, Bonczyk proceeded to file eleven
different notices and motions, all of which were denied.
Two days after the deadline to respond to the Court’s order to show
cause, Bonczyk filed her response. We accept this untimely filing. Upon
careful review of Bonczyk’s response, we conclude that she has failed to
show good cause as to why she should not be prohibited from continuing to
represent herself in this appeal.
Exercising this Court’s inherent authority to determine whether a pro
se litigant is abusing the judicial process, we now prohibit Bonczyk from filing
any further pro se motions, pleadings, petitions, notices, or any filings with
this Court, and require that any such filings be made by an attorney licensed
to practice law in Florida. See Jimenez v. State, 196 So. 3d 499, 501 (Fla.
3d DCA 2016); see also Brown v. Miami-Dade Cnty., 319 So. 3d 81, 84 (Fla.
3d DCA 2021) (affirming the county court’s determination of an appellant’s
vexatious litigant status where the county’s motion properly set forth “‘five or
more civil actions’ which had been ‘commenced, prosecuted or maintained
3
pro se’ by [the appellant] ‘over the immediately preceding 5-year period[.]’”
(quoting § 68.093(2)(d)1., Fla. Stat. (2019))); Hasanati v. State, 117 So. 3d
1157, 1158 n.1 (Fla. 3d DCA 2013) (finding that the appellant “abused the
judicial process through his repeated and meritless pro se appeals and
petitions” when he filed “[i]n less than three years . . . a total of seventeen
separate pro se appeals or petitions,” warranting a ban on further pro se
filings).
We direct the Clerk of the Third District Court of Appeal to refuse to
accept any such papers unless they have been reviewed and signed by an
attorney who is a duly licensed member of The Florida Bar in good standing.
Since Bonczyk is a licensed attorney, we have also sent a copy of this order
to the Florida Bar for referral.
This order shall take effect immediately. No motions for rehearing shall
be entertained.
So ordered.
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