Bryan Walters v. State of Florida, et al.
The Third DCA affirmed a non-final order declaring Walters a vexatious litigant under the recently enacted (2025) Florida Vexatious Litigant Act and requiring a $10,000 security. As a matter of first impression under the new statute, the court held that a security order under section 68.093(3) is in the nature of an injunction and therefore reviewable under Rule 9.130(a)(3)(B).
Key facts
- Pro se plaintiff Bryan Walters brought a 'civil negligence' action seeking ten billion dollars and declaratory/injunctive relief against the State and others.
- Appellees moved to declare Walters a vexatious litigant, identifying forty-five pro se cases finally and adversely determined against him within seven years (the statutory threshold is five).
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Holdings
- A non-final order entered under section 68.093(3) of the Florida Vexatious Litigant Act requiring a litigant to post security to proceed is in the nature of an injunction and is reviewable…
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Why it matters
This is an early appellate construction of the 2025 amendments to Florida's Vexatious Litigant Act (Ch. 2025-128), establishing that security orders under section 68.093(3) are immediately appealable as injunctions. It… — full analysis with a trial
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