According to Florida law, a two-year-old written warning by the trial court to a mother regarding the potential loss of residential custody if she continued to deny the father his post-dissolution visitation rights is deemed insufficient to notify the mother that a change of custody might occur as a result of a contempt hearing:
We reject the argument that sufficient notice was provided by the trial court’s written warning to the appellant in a 1997 order that she could lose residential custody if she continued to deny visitation. That two-year-old warning was insufficient to put the appellant on notice that a change of custody might occur as a result of this hearing. See Hart v. Hart, 458 So.2d 815, 816 (Fla. 4th DCA 1984).
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