JASON TODD WADE
v.
DIANA K. BJORKMAN WADE

Fla. 6th DCA | 2026-07-31
No. 2026-1804
Pratt, J., White, J., Kamoutsas, J.
2026 FL 9910 Florida District Court of Appeal, Sixth District (2026)

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Holding

A motion to disqualify that is not filed within 20 days of discovery of the facts constituting grounds for disqualification is untimely and properly denied.


Headnotes

[1] A motion to disqualify a judge must be filed within 20 days of discovery of the facts constituting grounds for disqualification, and failure to comply with this deadline…

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Key Quotes

“A motion to disqualify shall be filed within a reasonable time not to exceed 20 days after discovery by the party or party's counsel, whichever is earlier, of the facts constituting the grounds for the motion.”

Court citing Fla. R. Gen. Prac. & Jud. Admin. 2.330(g) as the basis for denying the petition

Facts & Procedural History

Petitioner Jason Todd Wade filed a motion to disqualify in a family law case and subsequently petitioned for writ of prohibition after the trial court…

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Opinion of the Court

SIXTH DISTRICT COURT OF APPEAL

STATE OF FLORIDA

Case No. 6D2026-1804 Lower Tribunal No. 2022-DR-001186

JASON TODD WADE, Petitioner,

V.

DIANA K. BJORKMAN WADE, Respondent.

Petition for Writ of Prohibition to the Circuit Court for Orange County.

July 31, 2026

PRATT, J.

Petitioner filed a petition for writ of prohibition in this Court seeking review of the trial court's order denying his motion to disqualify. We deny the petition because the motion was not timely filed. See Fla. R. Gen. Prac. & Jud. Admin. 2.330(g) (“A motion to disqualify shall be filed within a reasonable time not to exceed 20 days after discovery by the party or party's counsel, whichever is earlier, of the facts constituting the grounds for the motion."). Because the motion was untimely, we need not rule on the legal sufficiency of the motion.

Petitioner acknowledged the untimeliness of his motion in both his motion and his petition. Nevertheless, Petitioner frivolously filed his motion and his petition and in doing so unnecessarily wasted the trial court's and this Court's scarce judicial resources. We caution Petitioner that any further pro se filings in this Court asserting frivolous issues may result in sanctions such as a bar on pro se filing in this Court. See State v. Spencer, 751 So. 2d 47 (Fla. 1999).

PETITION DENIED.

WHITE and KAMOUTSAS, JJ., concur.

Jason Todd Wade, Lake Wales, pro se.

No Appearance for Respondent.


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