FAC Weekly Update: FAC v. Glass Trial Date Set and Amended Complaint Filed
Weekly update for September 29, 2026. This is recording number 392
Dear Members and Advocates,
There have been several significant developments in our landmark constitutional challenge to Florida’s registration scheme, and this week brought perhaps the clearest indication yet that the Court intends to keep this case on an expedited path. The Court has now set Monday, November 8, 2027, as the trial date in FAC v. Glass ET AL. At first glance, November 2027 may sound like a long way away. We understand that. But for a case of this magnitude and complexity, it really isn’t.
The scheduling order establishes June 1, 2027 as the deadline for filing motions for summary judgment (which almost certainly will be filed). Importantly, however, Judge Walker also made clear that the parties should file those motions at the earliest appropriate time, rather than simply waiting for the deadline. That is significant. It tells us that the Court is not interested in allowing this case to sit around for years while the parties engage in procedural maneuvering. The Court is paying close attention to this case, and the scheduling order reflects an expectation that the litigation should proceed expeditiously.
Let’s consider where we are already… The scheduling order entered yesterday is Document 146. 146 docket entries in a case that has been active for just over a month! There are now 30 attorneys who have entered appearances representing the various parties. This is not a small lawsuit. It is a massive constitutional case involving the State of Florida, FDLE, dozens of counties and numerous municipalities, each with their own attorneys, legal positions and procedural arguments. So, while November 2027 might look distant on a calendar, in the context of this litigation, it is coming remarkably quickly.
There is another important development today. Under the applicable rules, FAC had the right to amend its complaint without seeking additional permission from the Court, and we chose to use that opportunity proactively. Why you ask? Because during the early stages of this litigation, defendants have raised issues in motions to dismiss and others indicated during the September 11 scheduling conference that they intended to raise certain issues. Rather than waiting to deal with those arguments months from now in opposition to motions to dismiss, FAC and our attorneys addressed appropriate issues directly in the amended complaint. That is what you do when you are trying to move litigation forward rather than create unnecessary procedural delays. That’s also why we recently collected additional declarations. This way no defendant can say there’s no individual in their jurisdiction who would be able to bring this challenge on their own. We have plenty in each!
We are grateful to those of you who submitted a declaration. In under a week, we collected hundreds! Our membership is strong! Our membership is stepping up! Our membership is also growing! This month alone, we welcomed more than 80 new members to the FAC family. People who never knew we existed are reading about our lawsuit in the news and finding us on social media – thanks in large part to the efforts of our Media Committee who has been working tirelessly getting our message out there. According to YouTube analytics, month-to-date 67.2% of our traffic is from new viewers, showing that our content is reaching well beyond our existing audience. And surprisingly, unlike a decade ago, the public response has been supportive. Sure, we still get the venomous “woodchipper” commenters, but even that feedback is a welcome opportunity to educate the public with facts rather than the misinformation that was spreading for far too long while people remained silent and in the shadows. Now that we’ve got the public’s attention is the time to step up, get involved, lend your voice, volunteer your time, share our message, or support this fight financially – because when the public is finally listening, we need to make sure they hear from us.
There is one particularly important addition to the amended complaint. The amended complaint adds a claim for Civil Conspiracy. This is important because one of the challenges facing a lawsuit of this scope is that Florida’s registry system doesn’t operate in neatly separated boxes. The State has its statutes. Counties have their ordinances and registration responsibilities. Cities have their own ordinances and enforcement mechanisms. And FDLE maintains and administers the statewide registration system. But for the person actually living under “the registry”, these aren’t separate systems. They all operate together. Local law-enforcement agencies conduct address verifications. County Sheriff’s Offices handle registration. FDLE maintains the statewide system and coordinates the information and reporting framework. Law-enforcement agencies communicate information through that system, and the various jurisdictions enforce their respective requirements. As we’ve seen happen with increasing frequently lately, they all conduct “join operations” together.
The amended complaint therefore addresses the registry not simply as a collection of independent statutes and ordinances, but as an interconnected system. Even the challenged local ordinances and the actions of the local police department are functioning as components of the broader registration system which must be examined as part of the case as a whole. The civil conspiracy claim reflects that reality. The allegation is not simply that 50 different jurisdictions independently decided to violate the constitutional rights of registered citizens. It is that the various components of the entire system and all the parties operate collectively and in coordination, with FDLE at the center of the statewide framework and County and local agencies carrying out different pieces of that framework. The amended complaint helps explain that theory of the case and proactively addresses issues that defendants have already begun raising.
We have made a copy of the amended complaint available on the FAC v. Glass Status Update page. We strongly encourage everyone to read it and regularly check that page, where we will continue to post updates as they are filed with the Court. The case is moving along quickly. The Court is moving it. Our attorneys are moving it. And after only a little more than a month, we are already at Document 146, with roughly 30 attorneys involved and a trial date on the calendar. That may seem like a long road, but it isn’t. For a case this big, we’re just getting started!
Sincerely,
The Florida Action Committee
As of 9/29/2026 we are at 78% of our fundraising goal for this lawsuit! Help get us to the finish line by making a donation here: https://floridaactioncommittee.org/donations/
You can also make a tax-deductible donation to the Florida Action Foundation, Inc. (a 501(c)(3) entity) earmarked for this challenge by contacting [email protected]
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I just had a crazy thought and I wanted to get this posted before it got away from me. I think this would remove the state’s argument that changing the registration scheme has purely civil. So since I was told that by accepting the plea agreement I was gonna have to register once and never again, even if I moved. That’s basically part of the plea and if the state modifies that then they’re modifying my plea even if it wasn’t in writing it was still explicit in the agreement. And even if it’s not in writing in my plea agreement I’m sure there are plenty of plea agreements that happened prior to the registry changes that one of them has to have something along those lines actually in print. So I’m summarizing it as follows.
“The state constantly tries to eat its cake and have it too when it comes to historical plea agreements.
Back in 2000, I was the first person registered in Indian River County. Under the rules of that era, registration was a one-time, civil administrative intake for law enforcement use only. There wasn’t even a requirement to re-register if you moved. When I took my plea agreement, entering that one-time registration database was an explicit condition of my criminal sentence.
The state constantly hides behind the loophole that updating registry laws is just a ‘civil regulation’ so they can retroactively change the rules on us. But if a one-time required action woven into a criminal plea contract is retroactively turned into a lifelong, multi-annual obligation under threat of felony arrest, they aren’t just shifting civil rules—they are retroactively modifying the active conditions of a closed criminal sentence.
A plea agreement is a binding contract. The state shouldn’t be allowed to enjoy the benefits of having their contract closed decades ago while simultaneously eating the contract by fabricating brand-new penal conditions today.”
I always hope that people from legal read through the comments because we’re the ones being affected and we’re the ones who are going to notice contradictions and by scanning through the comments legal might just come up with some nuggets that they can use and some of them might be pyrite but Hey at least we try.
Legal is reading comments.
Reading this makes me happy that this is moving along at a good pace. I’m sure I’m not alone in my concerns for how long this would take, although I realize that it could still be delayed and even after an affirmative decision it will be appealed.
You can almost bet it will be appealed if there is an affirmative decision because the State of Florida will take a huge financial hit. They have alot of names on the regisstry that would probably get removed. Name=money to them. That all we are to them is dollars
I posted this in another forum….Mark Glass is Leaving the FDLE and taking a post as the Undersherrif in Miami Dade county. I am wondering if this is a coincidence?
Hire of new Miami-Dade undersheriff might ignite debate | Miami Herald https://share.google/hLnqSxOuM6lb1IORO
And
Who is Larry Keefe, Florida Department of Law Enforcement chief? https://share.google/WTNGAwcMYtK3XD26K
I I’ve seen the news, but it’s still way too early to tell what’s actually happening here. He might be eyeing a move to Miami-Dade, but since nothing is official yet, I’m waiting to see how things develop within those political circles.
I believe they officially annouced that Larry Keefe will be taking his spot but not sure when Mark Glass will be starting in Miami Dade
I looked into Larry Keefe, who was appointed to replace Mark Glass at FDLE. His history gives me reason to expect continued enforcement, but I haven’t found anything showing where he stands on registry reform.
As U.S. Attorney, he used strong language in sexual crime cases. In June 2019, discussing a case involving abuse of a minor, he talked about getting perpetrators “out of our neighborhoods and into our prisons.” Later that year, he described his office as “unyielding in its prosecution of these predators” after an undercover case involving attempted enticement and interstate travel.
In 2020, he promised to bring every investigative and prosecutorial resource available to protect children. In January 2021, he called a man convicted of new sexual crimes “a sexual predator who has repeatedly victimized underage girls.” Those statements were about specific criminal cases, so I wouldn’t use them to claim he views everyone on the registry the same way.
But his record also includes registration violations. In December 2019, he announced a 30-month federal prison sentence for a man who fled a Minnesota halfway house, moved to Florida, and failed to register under SORNA. The conviction announced in that release was failure to register, with no new sexual offense identified in that prosecution.
My concern is what approach he’ll bring to people who have completed their sentences and are trying to live within these rules. I haven’t found a clear statement from him about lifetime registration, residency restrictions, juveniles, or removal petitions.
Based on what I found, I’d expect enforcement to continue. I can’t honestly say he’ll be better or worse than Glass yet, but I don’t see a documented reason to expect reform from this appointment.
I hope that God hear us and have mercy and we prevail. Enough is enough with the abuse from the Big Brother. We are far from perfect, but we are human beings, most with families, loved ones and friends. So I hope this lawsuit will provide us with some reprieve because this registry thing…….. is becoming unbearable.