CURIAM. The Appellant, Warren Williams, appeals the order striking his rule 3.800(a) motion to correct an illegal sentence in Orange County case number 1984-CF-3189 as being improperly successive and barring him from filing any pro se motions. We agree that the court was in error in striking his rule 3.800(a) motion in that it appears, from the record, Williams was not afforded the procedural due process under State v. Spencer, 751 So.2d 47 (Fla.1999) (<HOLDING>). The State correctly concedes that Williams is
holding review of district court order imposing sanctions is by application for issuance of a writ of certiorari holding that trial court erred by imposing sanctions against attorney without notice and hearing but error was cured by attorneys subsequent challenge to sanctions holding that the district court committed reversible error by imposing criminal sanctions in a civil proceeding which did not afford the contemnor the procedural protections the constitution requires for the imposition of criminal contempt sanctions holding that motion for sanctions was not an independent cause of action and should be decided by trial court where frivolous pleading is pending holding that trial court must issue order to show cause which initiates a separate proceeding independent of the rule 8800 action before imposing sanctions