In re Forfeiture of $2,311.45 U.S. Currency, 559 So.2d 717, 718 (Fla. 1st DCA 1990). Moreland argues, and we agree, that the circuit court erred by granting summary judgment despite Moreland's defense that the money came from his Social Security benefits rather than from illicit drug dealing.
In In re Forfeiture of the Following Described Property: $2,311.45 U.S. Currency, Brown v. State, 559 So.2d 717 (Fla. 1st DCA 1990), this court held that default was improperly entered against a defendant who failed to appear in person or through counsel at a trial of civil forfeiture proceeding where the defendant was in prison and could not appear through counsel because he was indigent. In Brown v. Sheriff of Broward County Jail, 502 So.2d 88 (Fla. 4th DCA 1987), the district court reversed the trial court's order barring all future attendance at hearings by the prisoner who had filed a civil lawsuit.