¶1We reverse the portion of the trial court’s order imposing sanctions pursuant to State v. Spencer, 751 So.2d 47 (Fla. 1999). The trial court failed to issue an order to show cause before imposing the sanction. See Epps v. State, 941 So.2d *131206, 1207 (Fla. 4th DCA 2006). This portion of the order is quashed.
162 So. 3d 12
Jules v. State
District Court of Appeal of Florida
Decided March 12, 2014
District Court of Appeal of Florida · decided 2014-03-12
Relies on State v. Spencer
Decided 2014-03-12